Verification of identity – Beneficiary or non owner payee

If Sun Life remits a payment of $10,000 or more to a beneficiary on a death claim over the life of a non-tax exempt insurance policy or non-registered annuity, you must:

1. Create an information record of the person (name, address, date of birth, detailed occupation/pre-retirement occupation/principal business);
2. Verify the identity of the beneficiary using either the government issued photo ID method or the dual process method; and if applicable,
3. Take reasonable measures to determine whether a beneficiary to whom Sun Life makes a payment of $100,000 or more over the duration of a non-tax exempt life insurance policy or a non-registered annuity is a PEP, HIO, or family member or close associate of one of these persons; and
4. Collect the source of wealth (SOW) if the beneficiary answers yes to PEP/HIO determination.

For record keeping obligations the above information must be completed using the following forms:

Form 5089 Identity verification for beneficiaries – Individuals for these products:

• Non-tax-exempt permanent life insurance
• Non-tax-exempt Universal Life
• Non-registered accumulation annuities (AA)
• Non-registered payout annuities if $150,000 or more

Form 5092 Identity verification for beneficiaries non-owner payee – Wealth – Individuals for these products:

• Segregated Fund contracts
• Non-registered payout annuities if less than $150,000

Additional Information and Important notes:

• The information record and the VOI must be completed with the beneficiary prior to Sun Life first remitting the payment to the beneficiary in accordance with the regulations. If this is not completed within the 30-day provincial legislation for the claim (and if all other required claim documents have been received), Sun Life will move forward with the payment to the beneficiary. However, after this time of payment, you must continue to take reasonable measures to try and collect the information record and VOI.
• If a beneficiary is a minor, you must create an information record on the minor. The VOI is completed on the guardian/trustee/tutor or other representative along with PEP/HIO determination (if applicable).
• Acceptable VOI methods:
  • Government issued photo ID method: must be completed in person face-to-face.
  • Dual process method: can be completed either:
    • in person face-to-face,
    • through video conference
    • through secure email, fax, mail*

*Note:  If you are sending the form to the Client to complete via secure email, fax or mail, the Client must send you copies of the two source documents for you to refer to the information provided on the form.

If the beneficiary is an Entity:
If Sun Life remits a payment of $10,000 or more to the beneficiary on a death claim over the life of a non-tax exempt life insurance policy or a non-registered annuity , you must:

1. Create an information record of the entity: name, address, detailed principal business.
2. Verify the identity of the Entity (it’s existence) and record the names of the directors (if applicable).
3. Record additional information for all entity types and confirm the accuracy of this information.
4. Record and confirm the accuracy of the entity’s control, structure, and beneficial ownership through an attestation.
5. Obtain additional information on who has power to bind a corporation (only applicable for corporations – (through a corporate resolution document and certification).

For record keeping obligations the above information must be completed using the following forms:

Form 5115 Identity verification for entity beneficiaries for these products:

• Non-tax exempt permanent life insurance
• Non-tax exempt Universal Life
• Non-registered accumulation annuities (AA)
• Non-registered payout annuities if $150,000 or more

Form 5094 Identity verification of an entity beneficiary - Wealth for these products:

• Segregated Fund contracts
• Non-registered payout annuities if less than $150,000

Form 5114 Corporate Resolution for a beneficiary that is a corporation (for all corporations)

Sun Life will complete a corporation search to confirm:

• the corporation’s existence;
• name and address of the corporation and
• the accuracy of the names of the directors that have been recorded on the form.

You must confirm the accuracy of certain information collected and recorded on the form. This can be completed by doing the following:

• If an Estate: Get a copy of the will, court order or death certificate
• If a Trust: Get a copy of the trust deed or other documents establishing the trust
• Partnership: Get a copy of the partnership agreement
• Corporations: Complete Appendix A and B on form 5115 - Identity verification for entity beneficiaries
• Other non-corporate entity: Get a copy of non-corporate entity records

The VOI and other information collected on the beneficiary must be completed by a Life Licensed individual. This includes the individuals below:

• Sun Life Advisor
• Service Associate

An estate beneficiary is to be treated as an “entity other than a corporation.” Therefore, we are required to follow the Entity requirements which include:

• VOI of the Estate. This means confirming the existence of the estate for VOI purposes – a copy of a death certificate, will or court order to confirm the name and address (if there is one) of the estate.
• Beneficial Ownership Requirements – collecting and confirming the ownership, control, and structure - this is collecting and confirming the accuracy of the names and addresses of:
  • the executor of the estate
  • the known beneficiaries of the estate.

You collect this information on the form and an attestation is built into the form to confirm the accuracy of the information provided.

You must record the names of all the known beneficiaries of the Estate including beneficiaries that are receiving non-monetary items.

If you are using the dual process method face-to-face or by video conference, you do not need to send copies of the source documents.

If you are using the dual process method by secure email, mail or fax, with a beneficiary you must send copies of the source documents used to confirm the identity of the beneficiary and refer to this information. This only applies to the death claims process.

The 4830 is worded for new applicants and not for beneficiaries. For this reason, you need to complete either:

• Form 5089 - Identity verification for beneficiaries – Individuals or
• Form 5092 - Identity verification for beneficiaries/non-owner payee-Wealth – Individuals

Yes. The SA can collect and complete the VOI process for a beneficiary if the SA holds a life insurance license.

You must notify the claims department that the individual beneficiary has an existing Sun Life product where VOI and AML information has been previously collected. Sun Life will determine if the existing information on file can be used.

At the time of notifying the claims department, you must provide the beneficiary’s:

• Existing policy or contract number,
• Full name,
• Residential address, and
• detailed occupation/pre-retirement occupation/principal business

If Sun Life does not have VOI and AML information for the beneficiary, you must complete the applicable VOI form.

You must notify the claims department that VOI and AML information has been previously collected for the entity beneficiary. Sun Life will determine if the existing information on file can be used.

At the time of notifying the claims department, you must provide the documents that were used for VOI at time of application opening that support the below:

• Existing policy or contract number,
• Entity’s name,
• Entity’s address,
• Names of the directors of the board, and
• Beneficial ownership, control and structure

If any of the above information has changed since account opening, then Sun Life will review the information and communicate if it can be accepted or if new forms must be completed.

Sun Life will ask for VOI if a funeral home was named as the beneficiary unless it meets one of the exemptions to record keeping requirement and when to VOI an entity. Refer to exemption requirements.

For policies issued in a foreign jurisdiction (e.g., Bermuda, Cuba, United Kingdom, Jamaica, etc.).

It is the entity that triggers the AML requirements, i.e., Sun Life Assurance Company of Canada (SLACC). As SLACC is a Canadian regulated life insurance company, Sun Life must apply Canadian AML laws to all its businesses (even if the transactions are happening in foreign places with foreign policyholders).

As a result, we will need to apply the VOI requirements for beneficiaries for policies with a foreign jurisdiction.