Before You Sell Another Annuity, LTC, or Flood Policy in Kentucky — Read This First

If you're a licensed Kentucky insurance producer who sells — or plans to sell — annuity products, long-term care insurance, or NFIP flood policies, there are specific training requirements that must be completed before you write your first policy in each category. These are not suggestions. They are mandatory pre-sale requirements enforced by the Kentucky Department of Insurance, and selling without completing them puts your license at risk. This guide covers exactly what each requirement is, when it applies, how it interacts with your regular CE obligations, and what happens if you skip it.

Annuity Best Interest Training: What Changed and Why It Matters

Kentucky adopted the NAIC Best Interest model regulation for annuity transactions, codified at 806 KAR 12:120, with an effective date of January 1, 2022. Every producer who recommends or sells any annuity product in Kentucky must complete a 4-hour Annuity Best Interest training course as a one-time requirement before doing so. This is not a renewal of an earlier suitability training requirement — it is a new standard, and prior suitability training completed under the old Kentucky annuity regulation does not satisfy it.

The shift from suitability to Best Interest is more than a terminology change. Under the suitability standard, a recommendation was acceptable as long as it was suitable for the client given their financial situation. Under the Best Interest standard, a recommendation must be in the client's best interest — a higher and more demanding obligation. The training covers four specific obligations that every producer must understand and apply.

The care obligation requires you to exercise reasonable diligence, care, and skill to know the consumer's financial situation, understand the available options, and have a reasonable basis to believe the recommended annuity effectively addresses the consumer's needs over the life of the product. The disclosure obligation requires you to disclose your role in the transaction, the compensation you will receive, and any material conflicts of interest. The conflict-of-interest obligation requires you to identify and manage conflicts between your financial interests and the consumer's interests. The documentation obligation requires you to maintain records of the information collected, disclosures made, and the basis for your recommendation.

Insurers are required to verify that agents have completed this training before allowing them to sell annuity products. If you attempt to place an annuity with a carrier before completing the training, the carrier should flag the missing requirement — but do not rely on the carrier to catch your gap. The obligation is yours.

This 4-hour training counts toward your regular 24-hour biennial CE requirement in the period in which it is completed, making the one-time obligation less burdensome than it might initially appear.

How Kentucky Compares on Annuity Best Interest Timing

Kentucky's January 1, 2022 effective date makes it one of the earlier adopters of the NAIC Best Interest model in the region. If you completed Best Interest training in another state before coming to Kentucky, check with the KDOI about whether substantially similar training satisfies the Kentucky requirement.

Long-Term Care Insurance Training: Initial and Ongoing

Life and Accident & Health licensees who sell, solicit, or negotiate long-term care insurance in Kentucky must complete a 4-hour initial LTC training course before engaging in LTC sales for the first time. This is a one-time initial requirement. After completing the initial course, a 1-hour LTC refresher course must be completed during every subsequent renewal period to maintain your authority to sell LTC products.

Both the initial 4-hour and ongoing 1-hour refresher credits count toward your 24-hour CE requirement in the applicable renewal period. The LTC training obligation does not stack on top of your CE requirement — it partially satisfies it.

The ongoing refresher requirement is not optional and does not expire based on experience. It does not matter how many LTC policies you have written or how many years you have been selling LTC products — the 1-hour refresher is required every renewal period as long as you continue selling LTC. Producers who miss a renewal period's refresher risk losing their authority to sell LTC products until the requirement is satisfied.

Long-term care insurance is one of the most important and underutilized coverage categories in Kentucky's aging population. The state's rural communities in particular face significant unmet LTC planning needs, and producers who develop genuine expertise in LTC — combined with staying current on the ongoing training requirement — serve a critically important market.

NFIP Flood Insurance Training: A One-Time Requirement With Real Stakes

Agents who sell NFIP flood policies in Kentucky must complete a 3-hour one-time flood insurance training course before writing their first flood policy. This training covers the basics of NFIP coverage, eligibility, flood zone determinations, rating, and the community participation framework that governs which properties in which communities have access to NFIP coverage.

The 3-hour NFIP credit counts toward your regular CE total in the period of completion. Given that the training is a one-time requirement and the 3 hours satisfy CE obligation simultaneously, there is no good reason to delay completing it if you work with any clients who have potential flood exposure.

Flood insurance is critically important in Kentucky. The state's complex river system — including the Ohio, Kentucky, Green, Cumberland, and Licking rivers — creates significant flood exposure for properties throughout the state. The catastrophic eastern Kentucky floods of 2021 and 2022 caused devastating losses in communities where many affected properties lacked flood coverage. Agents who are equipped to identify flood exposure, explain NFIP coverage, and write flood policies serve their clients in a genuinely important way — and agents who are not equipped to have that conversation are leaving their clients exposed to one of the most common and costly risks in the state.

Specialty Training Comparison: Kentucky vs. Comparison States

Wisconsin has the most demanding LTC requirement in the comparison group — 8 hours initial plus 4 hours ongoing per renewal period, with specific Wisconsin Medicaid/BadgerCare Plus content required. Kentucky's 4-hour initial plus 1-hour refresher is more streamlined while still maintaining an ongoing competency requirement.

Frequently Asked Questions

• Do I need to complete Annuity Best Interest training before I can sell any annuity product in Kentucky? Yes. You must complete the 4-hour Annuity Best Interest training under 806 KAR 12:120 before selling, soliciting, or negotiating any annuity product in Kentucky. Insurers are required to verify completion before allowing you to sell their annuity products. This is a one-time requirement — once completed with an approved provider and reported to the KDOI, you do not repeat it in future renewal periods.
• What happens if I sell an annuity in Kentucky before completing the Best Interest training? Selling an annuity without completing the required Best Interest training violates 806 KAR 12:120 and Kentucky's producer conduct standards under KRS Chapter 304. This can result in KDOI disciplinary action including fines and potential license suspension. The insurer may also face regulatory consequences for allowing an undertrained agent to sell on its behalf. Do not sell first and train later.
• I completed LTC training several years ago. Do I still need the annual 1-hour refresher? Yes. The 1-hour LTC refresher is required every renewal period as long as you continue selling LTC products in Kentucky. There is no experience-based exemption from the ongoing refresher requirement. Completing the initial 4-hour course satisfied the initial training obligation — it did not eliminate the ongoing renewal obligation.
• Is NFIP flood training required even if I only write flood policies occasionally? Yes. The 3-hour one-time NFIP flood training is required before you write your first NFIP flood policy, regardless of how frequently you intend to sell flood coverage. The requirement is not volume-based. The good news is that the 3 hours count toward your regular CE total and the training is a one-time requirement — complete it once and it is done.
• If I completed Annuity Best Interest training in another state, does it satisfy Kentucky's requirement? This depends on whether the other state's training is considered substantially similar to Kentucky's 806 KAR 12:120 requirement. Contact the KDOI at (502) 564-6004 or DOI.LicensingMail@ky.gov to confirm whether your out-of-state training satisfies the Kentucky requirement before selling annuities in the state. JustInsurance's Kentucky-approved specialty training courses cover Annuity Best Interest, LTC initial and refresher, and NFIP flood — everything you need to sell these products in Kentucky with confidence and full regulatory compliance. Enroll at JustInsurance today and make sure you are trained before you sell.