PPLI Providers: Carrier Names, Evidence and Comparison Criteria

Which companies are documented as PPLI providers?

The Senate Finance Committee's February 2024 staff report, page 6, names Lombard International, Zurich American Life Insurance Company, Prudential Insurance Company of America, Investors Preferred, John Hancock, Crown Global Insurance Group and Pacific Life Insurance Company as the seven providers it understood to be largest for U.S. clients.

Read that as a snapshot from a 2024 investigation, not an endorsement or a current league table. Also bear in mind that the brand you hear, the business that distributes the policy and the insurer that issues it can all carry different names. The one that matters is the entity named in the policy, because it owes the contractual obligations.

These findings reflect only the materials we reviewed. If we could not find a current document, that does not mean the carrier has stopped writing the product, never offered it or turns every applicant away. Equally, a public product page is not an offer to you.

For product mechanics, read the private placement life insurance guide. For the selection process, use the carrier due-diligence framework.

Comparing PPLI providers? Start with the questions that matter. A provider name is only a starting point. If you are reviewing a proposal or beginning a comparison, tell us what is unclear.

• Issuer: Which legal entity would issue the policy?
• Costs: Which policy, investment and administration charges are included?
• Access: What restrictions or charges apply to withdrawals and surrender?
• Evidence: Which documents or assumptions are still missing?

Ask about my provider comparison. No policy documents are needed for your first question.

What happened to Lombard International?

It is often said that Lombard simply disappeared. In fact there were two separate transactions, and it helps to follow each legal entity and business division.

• U.S. and Bermuda business: The company's rebrand announcement states that the business became Axcelus Financial on January 22, 2024, following BroadRiver's acquisition in the previous year.
• Luxembourg business: Utmost reported the integration and rebrand on November 5, 2025, following acquisition in December 2024. The Belgian regulator's entity record dates the name Utmost Luxembourg S.A. from October 20, 2025, following Lombard International Assurance S.A.

If you hold an existing policy, the new brand name will not tell you which entity is now responsible for it. Check its issuer, any transfer or endorsement documents and current service correspondence. The Lombard and successor-entity profile provides the related research route.

For non-U.S. proposals, begin again with the local product, issuer and relevant countries. A Luxembourg or Liechtenstein policy and a U.S.-tax-qualified PPLI policy can have materially different operating requirements. Whether the owner's country recognizes the policy is a separate question, however well known the group.

How this comparison uses evidence

Public sources are good for names, published products, dated corporate events and regulatory actions. They cannot give you a quote for a particular insured. A sound comparison shows what kind of evidence sits behind each entry.

1. Identify the entity. Record the exact legal name, domicile, regulator and role in the proposal.
2. Date the document. Distinguish its publication or effective date from the date someone downloaded it.
3. State the evidence limit. Mark a figure as a contractual term, an illustration, a public disclosure or an unanswered request.
4. Compare like with like. Use the same insured, funding, investments, withdrawals and time horizon.
5. Resolve material gaps. Obtain written answers before treating an assumption as a decision fact.

We do not guess at undisclosed prices, and we do not mark a carrier down for information we could not find. A document we did not locate may well exist elsewhere. See PPLI.com's editorial standards for the site's stated approach to sources and corrections.

Prepare a proposal comparison record

Use a separate sheet for each proposed contract. Include the document title, issuer, effective date and exact page or clause. Label each answer public, confirmed in writing or outstanding. An unanswered item remains an open question.

• Legal issuer: Company name, regulator, domicile and the entity responsible for each guarantee.
• Client and state: Written acceptance of the intended owner, insured, trust and relevant U.S. state.
• Tax framework: Contract qualification, MEC design and any foreign-issuer tax or reporting analysis.
• Financial evidence: Issuer statements and dated rating actions, with parent and subsidiary figures kept separate.
• Protection: The contract clause and law governing separate-account assets, exclusions and remaining exposures.
• Investments: The eligible vehicle, manager, valuation cycle, redemption terms and control boundaries.
• Premiums and costs: Dated funding limits, all policy and investment charges, and outcomes under adverse assumptions.
• Access and exit: Loan rates, collateral terms, surrender charges, lapse scenarios and net proceeds.
• Roles and compensation: Who advises, places and services the policy, and every fee, commission or referral payment.

For each criterion below, record the proposed term, source document, date, responsible party and unresolved question. Add a column for what would make the proposal unacceptable. Examples include an unapproved ownership structure, cash access that misses a required payment date or a material charge missing from the illustration.

Before engaging an adviser or intermediary, obtain written disclosure of their role and any fee, commission or referral payment connected with the case.

Build your PPLI research file

Keep the proposed policy, offering memorandum, investment documents, charge schedules and legal analysis together. PPLI.com's PPLI guide covers the foundation, and the research library provides topic-specific reading.

To ask about available briefing material, send your research question and explain the decision you are preparing to make.

Nine criteria for comparing PPLI proposals

1. Issuing entity, domicile and authorization

Match the legal name on the policy with the appropriate regulator's record. For example, the CAA register identifies Luxembourg life insurers. Read each register entry together with the activities and territories it covers.

Ask separately where the product can be sold, who may own it, who may be insured and how it is treated where each relevant person is taxed. Domicile matters, but it will not tell you on its own whether another country recognizes the policy for tax or whether the insurer will accept the applicant.

2. Financial strength and solvency evidence

An insurer financial-strength rating is an opinion about financial capacity to meet insurance obligations. It does not guarantee payment, suitability or investment performance. AM Best's rating definitions describe that distinction.

Record the rated legal entity, rating type, agency, publication date and outlook. A group rating does not automatically carry down to each subsidiary. And a strong letter grade for the insurer says nothing about the risk of the portfolio inside your policy.

Read solvency ratios under their own frameworks. Solvency II Article 101 specifies a one-year 99.5% Value-at-Risk calibration for the Solvency Capital Requirement. The Swiss Solvency Test has its own methodology. The same ratio can mean a different cushion under a different regime, so compare the definitions and assumptions first.

3. Separate-account assets and insolvency treatment

Read the governing law and the contract together. Delaware Section 2932(a)(5) makes protection of the specified assets from liabilities of other insurer business conditional on the contract. New York Section 4240(a)(12) also makes the agreement material. State laws are not worded identically, so check the law that governs the actual account.

For Luxembourg, examine the assets representing technical provisions, their inventory and custody arrangement. The February 2026 consolidated version of CAA Circular 16/9 describes the relevant deposit arrangements and statutory priority. Priority over an identified pool of assets is valuable, but it does not guarantee what those assets will be worth or that you can reach them quickly in an insolvency.

For Liechtenstein, Insurance Supervision Act Article 161 addresses a special estate for insurance claims in bankruptcy. Solvency II Article 275 provides the broader European insurance-claim priority framework. Ask counsel to identify the national provisions and proceedings that apply to the actual issuer.

Claims by the policyowner's own creditors are a separate matter. Protection if the insurer fails does not shield the owner from personal creditors, give a right to compensation-scheme payments or protect against investment losses.

4. Custody and asset access

Identify the custodian, account structure, applicable agreement and any subcustody arrangements. Determine which assets the agreement covers, whether any account is excluded and what happens if the insurer, bank or investment manager fails.

For Luxembourg, use the current CAA custody text rather than relying on the market label Triangle of Security. The consolidated circular includes the model agreement and regulator approval requirements. Obtain confirmation that the proposed custodian and investments are accepted for the actual policy.

5. Investment platform and permitted fund structures

Request a dated list of approved options with share classes, fees, liquidity and restrictions. Access to one of a manager's funds does not mean access to all of them. Prudential's April 2026 document, for example, identifies particular state, allocation, approval and client restrictions.

For U.S. diversification look-through, Treasury Regulation 1.817-5(f) sets ownership and access conditions, including exceptions for specified non-separate-account investors. Calling a fund insurance-dedicated does not make it so; it must meet those conditions. At the same time, the regulation does not require that no other investor ever hold an interest.

For Luxembourg, CAA Circular 26/1 applies from February 1, 2026 to newly issued contracts, with provisions for existing contracts and funds. Section 2 sets standard category thresholds:

The circular defines movable wealth and permits a request for higher classification subject to specified conditions. These are Luxembourg investor categories, not PPLI premium minimums. Apply the category, fund type, asset rules and transition provisions together. Section 7.3.2 expressly lets insurers offer narrower strategies than the regulatory maximum, and even Type D does not open the door to every conceivable asset.

6. Diversification and investor-control procedures

For a U.S. variable contract, obtain the calculation under Section 817(h) and the applicable Treasury regulation. The general 55/70/80/90 concentration limits operate alongside aggregation, look-through, timing and other provisions. Ask who monitors the account, how exceptions are escalated and which party is responsible for addressing a failure.

Treasury Regulation 1.817-5(c) generally tests diversification at the end of each calendar quarter or within 30 days afterward. Apply the definitions and the start-up and market-fluctuation provisions where relevant. Relief for an inadvertent failure under paragraph (a)(2) is conditional, including requirements concerning correction and payment; relief is not automatic.

Investor control is a separate question. Revenue Ruling 2003-91 and Revenue Ruling 2003-92 reach their conclusions on specified facts. Different adviser arrangements and communications can lead to different results.

In Webber v. Commissioner, 144 T.C. 324 (2015), the court examined actual direction and retained powers over the investments. The lesson is to write down the permitted operating arrangement and then stick to it. The case turned on how the investments were actually directed, not simply on who selected the manager.

Obtain the appointment process, discretion terms, permitted communications, related-party restrictions and monitoring records. Section 817(h)(5) expressly permits independent investment advisers. Look at the facts of the proposed relationship. Being able to choose a manager neither guarantees compliance nor automatically breaks the rules.

7. Minimum premium and acceptance requirements

Ask for the proposed insurer's current minimum, permitted payment schedule, underwriting requirements and investor tests. Regulatory category thresholds, fund minimums and carrier minimums are three different things.

For example, Investors Preferred's disclosure states specific licensed-state and accredited-investor/qualified-purchaser restrictions. Other providers set their own conditions. The PPLI minimum investment guide separates legal eligibility from commercial acceptance and economic suitability.

8. Policy economics and cash flows

Obtain all costs in their contractual form: fixed amounts, percentages of premium, charges on policy value, insurance rates, investment expenses, distribution payments and exit costs. Then model their dollar effect under common assumptions.

A single annual percentage can hide a different base or a charge that changes over time. Compare net cash values, surrender values, death benefits and available cash at relevant dates. Keep guaranteed terms separate from illustrations, and disclose any investment or funding difference between the proposals.

Run low-return, high-charge and early-exit scenarios. If a policy loan is contemplated, include loan interest and the consequences of lapse. See PPLI costs and economics.

9. Cross-border treatment and insurer tax elections

Obtain written confirmation of acceptance for the proposed owner, insured, beneficiaries and jurisdictions. Separately analyze tax recognition, reporting and possible changes of residence. Knowing the insurer may sell to you does not answer the tax questions.

For a foreign insurer, verify any Section 953(d) election and its effective period. Revenue Procedure 2003-47 describes approval evidence and its connection with premium excise-tax exemption. The election governs the insurer's own tax treatment. The policyowner's reporting and foreign tax position still need their own analysis.

U.S. securities eligibility is separate. Rule 501 includes multiple accredited-investor categories. Section 2(a)(51) defines qualified purchasers, including a natural-person category with at least $5 million in investments. Check which test the particular offering uses; eligibility does not come down to a single wealth figure.

Read the related carrier profiles

• Lombard International and successor businesses: follow the U.S., Bermuda and Luxembourg entity histories.
• Swiss Life: examine the group, issuing entities and relevant regulatory records.
• Pacific Life: separate its historical inclusion in the Senate report from current product evidence.

Check the dates and sources in each profile. For the current terms of a proposed policy, go to the insurer's own documents.

What do the regulatory records establish?

Identify the named entity, conduct period, authority, decision date and documented outcome. Preserve the difference between an allegation, an admission, a sanction, a remediation plan and a verified completion.

Lombard International Assurance S.A.: 2024 CAA sanction

The CAA's March 20, 2024 notice reports a January 10, 2024 administrative decision imposing a €1,682,000 fine for anti-money-laundering and counter-terrorist-financing control failures. The notice also records cooperation and an initiated compliance plan subject to close monitoring. That is different from a finding that every deficiency had been fixed.

Swiss Life entities: 2021 U.S. agreement

The DOJ announcement of May 14, 2021 identifies Swiss Life Holding AG, Swiss Life (Liechtenstein) AG, Swiss Life (Singapore) Pte. Ltd. and Swiss Life (Luxembourg) S.A. in a deferred prosecution agreement concerning assistance to U.S. taxpayers in concealing assets and income.

DOJ reported an agreed total payment of $77,374,337 and described cooperation and remedial measures. The agreement and attached statement of facts provide the terms and admissions. For what happened afterwards, look beyond the announcement.

Neither record, on its own, tells you whether the insurer is suitable today. Ask for evidence of what has happened since and how controls work now. Do not assume that both groups changed ownership, or that remediation is complete, without records showing it. Review the CAA's sanctions publications and the relevant authorities' records for the actual issuer.

How should proposed legislation affect the comparison?

S. 4279 was introduced on April 13, 2026. The official introduced-bill record and bill-status file reviewed for this page record referral to the Senate Finance Committee. The introduced text proposes changes to the tax treatment of applicable private placement contracts, including special rules for certain foreign-issued contracts.

Ask the insurer to distinguish its current contractual obligations from an opinion about future law. Obtain the change-of-law, policy-change, exchange and surrender provisions. No carrier can promise what Congress will enact. The 2026 Senate proposal analysis addresses the introduced provisions and their proposed effective dates.

PPLI provider questions

Prepare your carrier-selection question

Identify the proposed issuer, the countries involved and the point you need to resolve. For example: which entity owes the death benefit, what limits access to cash, or which costs are missing from an illustration? State any U.S. connection, the intended ownership structure and your main objective. Obtain engagement and compensation disclosures before proceeding.

Send a PPLI provider question or email info@ppli.com.

This page provides educational research. It does not replace analysis of a policy and its legal, tax, investment and insurance implications by appropriately qualified professionals.