Compliance Manual

American-Amicable Life Insurance Company of Texas

This manual outlines the proper procedures for doing business with the above referenced Waco based companies. As changes are made, updated pages will be mailed to you for inclusion in the manual. Insurance coverage in our society has always been an important element of family protection. More recently it is seen as a necessity and for that reason the insurance industry is under increasing scrutiny. Government regulatory agencies in conjunction with the courts impose a duty and a responsibility on agents and insurers to conduct their business in accordance with current rules and laws. We must comply with these obligations. Failure to do so may result in fines, penalties, agent investigations, market conduct examinations, litigation, punitive damages and revocation or suspension of a license to do business. Customer satisfaction is of utmost importance to the above referenced group of companies. Providing excellent customer service and following ethical sales practices will reduce consumer and department of insurance complaints, cancellations and rejections and eliminate fines and litigation. The Company and you can maintain a reputable industry standing only by satisfying the customer and strictly following state and federal requirements as well as Company guidelines. These guidelines are provided as an educational and training device to assist you the agent in proper marketing and solicitation procedures. Please take time to read the following document and direct any questions that you may have covering same to your field manager or the Home Office Marketing Department. It is your responsibility to understand this document in its entirety. Best wishes for your success.

ETHICS LINE

American-Amicable Life Insurance Company of Texas is serious about ethical behavior and compliance with the law. To this end, we have established a toll-free number for you to report any suspected unethical behavior or compliance violations. If you suspect any such violations, please contact Ethics Line at:

PHONE 1-800-500-0333

FAX 1-800-500-0993

TO REPORT SUSPECTED UNETHICAL BEHAVIOR AND COMPLIANCE VIOLATIONS

AMERICAN-AMICABLE LIFE INSURANCE COMPANY OF TEXAS

AGENTS CODE OF PROFESSIONAL ETHICS

1. I will fully comply with all ethics and compliance standards and procedures established and communicated to me by the Company.

2. I will fully comply and remain current with the laws and regulations of the jurisdictions that I am licensed to conduct business in for the Company, and will obtain all required licenses and appointments.

3. I will attempt to discover and understand the needs and financial circumstances of my clients, to fully explain the Company’s products and services, and make every effort to provide the same quality and level of service to my clients that I would expect for myself.

4. I will not negotiate or deposit any funds payable to the Company or payable to any payee other than myself or my immediate family, except as provided in my Agent’s Contract, nor will I create any legal obligation for the Company that is not within the scope of my authority.

5. I will conduct myself in a professional manner and will accept the decisions made by the Company and its employees, and will treat them with the same respect I expect for myself.

6. I will not make, modify or discharge contracts; extend the time for paying premiums; waive any of the Company’s rights or requirements; bind the Company by any statement, promise or representation; agree with any applicant to an extra premium for extra risks; or collect any money other than as provided in my Agent’s Contract.

7. I will only use appropriate sales material and illustrations approved by the Company and will include all appropriate disclaimers. I will not advertise or publicize the Company’s name by using it in any advertising or publicity medium unless the Company has approved the content in writing. I will not alter, affix stamps or labels to, or otherwise modify policies, policy envelopes, sales illustrations, or literature provided by the Company.

8. All signatures on applications or other documents submitted by me will be authentic. I will not sign another person’s name, nor will I sign as a witness to any person’s signature on any application or other form relating to the Company’s business unless the signature is written in my presence or otherwise noted on the form.

9. I will deliver all policies and contracts to the policy owner in a timely manner.

10. I will not be the assignee, owner or beneficiary of any policy issued by the Company other than a policy on myself or on a member of my immediate family. The President or Compliance Officer of the Company may authorize an exception in writing.

11. I will not enter into any contracts with any sub-producers for the solicitation of insurance or share commissions with anyone not licensed and appointed with the Company, unless otherwise authorized to do so in writing by the Company.

12. I will not represent the Company in any manner at all before any State Insurance Department or official, or before any governmental agency, without first consulting with and receiving specific prior written approval of the Company.

13. I will not charge for services provided to any applicant, policy owner, beneficiary, or assignee, such as for explaining the terms of a policy, collecting policy proceeds, making or submitting proofs of claim, or settlement of any claim, or any similar service.

14. I will not make any disparaging remarks or use any disparaging literature about the Company’s competitors.

COMPLIANCE POLICY

OUR RESPONSIBILITY

Insurance coverage in our society has always been an important element of family protection. More recently it is seen as a necessity and for that reason, the insurance industry is under increasing scrutiny. Government regulatory agencies, in conjunction with the courts, impose a duty and a responsibility on agents and insurers to conduct their business in accordance with the current rules and laws. We must comply with these obligations. Failure to do so may result in fines, penalties, agent investigations, market conduct examinations, litigation, punitive damages and revocation or suspension of a license to do business. Customer satisfaction is of utmost importance to American-Amicable Life Insurance Company. Providing excellent customer service and following ethical sales practices will reduce consumer and department of insurance complaints, cancellations and rejections, as well as eliminate fines and litigation. The Company and you can maintain a reputable industry standing only by satisfying the customer and strictly following state and federal requirements as well as Company guidelines.

ADVERTISING

Any advertisement as defined below, including recruiting advertisements, must be reviewed and approved by the Compliance Department prior to its printing or use. You must submit all proposed advertising to the Marketing Sales Department. Marketing will work with the Compliance Department, which will check the specific state and federal advertising regulations in order to assure compliance and avoid penalties or litigation resulting from the improper use of advertising material. Any advertisement which is used without the Compliance Department’s approval will result in immediate disciplinary action. There are certain states and products where an advertisement is required to be filed and approved by the Department of Insurance prior to its use. The Home Office is responsible for filing and obtaining approval of all such advertisements. Where required, no advertisement may be used until state approval has been obtained. Advertising is any kind of written, audio, or visual device designed to create public interest in insurance products or an insurer, or to induce the public to purchase, increase, modify, reinstate, or retain a policy. The definition of advertisement includes: 1. Printed and published material, audio visual material, and descriptive literature of an insurer used in direct mail, newspapers, magazines, radio scripts, television scripts, billboards, and similar displays; and 2. Descriptive literature and sales aids of all kinds issued by an insurer, agent, producer, broker or solicitor for presentation to members of the insurance-buying public, including but not limited to, circulars, leaflets, booklets, depictions, illustrations, form letters and lead-generating devices of all kinds; and 3. Prepared sales talks, presentations and material for use by General Agents and agents, whether prepared by the insurer or the General Agent or agent; and 4. Material used for the recruitment, training, and education of an insurer’s sales personnel, and General Agents, which is designed to be used or is used to induce the public to purchase, increase, modify, reinstate, or retain a policy; and 5. Material included with a policy when the policy is delivered and material used in the solicitation of renewals and reinstatements.

Three Categories of Advertisements

1. “Institutional Advertisement” means an advertisement having as its sole purpose the promotion of the reader’s, viewer’s, or listener’s interest in the concept of life insurance or Annuities Examples: any form of advertisement that promotes only the name and/or financial standing of an insurance company or agency.

2. “Invitation to Inquire” means an advertisement having as its objectives the creation of a desire to inquire further about insurance and which is limited to a brief description of coverage. Examples: flyers with the Company’s or Agency’s phone number and/or address, anything with a response card, lead-generating devices, audio and/or visual advertisements giving the Company’s or Agency’s phone number and/or address.

3. “Invitation to Contract” means material used to induce the public to purchase, increase, modify, reinstate, or retain a policy. It gives detailed information regarding the policy rather than just a brief description as seen in the “Invitation to Inquire.” This category has the strictest requirements. It is the Home Office’s responsibility to create this type of advertising and provide it to the field. Examples: brochures, sales kits, etc.

Advertising Review Procedures

In order to comply with state insurance law, the following procedures have been established

for advertising review and approval:

1. Submit a clean copy of the advertising piece to the Marketing Sales Department.

2. Indicate the product name and policy/rider form number(s) for which the piece will be used.

3. Indicate the intended method of dissemination, including:

* whether the piece is for agents or the insurance-buying public

* whether or not the piece will be mailed

4. Indicate the states where the piece will be disseminated.

5. Provide back-up documentation to support any statistics or quotes and clearly cite the source providing the author, title, and date.

6. Detail exclusions and limitations as prominently as benefits.

7. All text must be in at least 10 point type.

8. If known, indicate the dates you might use the piece and the quantity you intend to produce and disseminate.

Marketing will review every advertising piece to be sure it meets company standards regarding overall appeal, potential benefit, and compliance detail. Marketing will forward the submission to the Compliance Department for review. If approved by Compliance, a copy of the advertisement material will be returned to the agent with notification of approval. If the advertisement is disapproved by Compliance, notification will be sent to the agent with comments as to why it cannot be used. If revisions are required, Marketing will work with the submitting agent to bring the piece into compliance and resubmit revised piece to the Compliance Department. Questions regarding the status of a submission should be directed to the Marketing Sales Department. Once approved, the piece will be produced with a unique control number located in the vicinity of the lower right-hand corner. Eight original samples of the approved version must be forwarded to the Home Office Marketing Sales Department, as every advertisement must be in our Compliance files in accordance with state insurance laws. Again, it is the Home Office Compliance Department’s responsibility to be aware of each state’s advertising requirements and to insure the proper compliance with these requirements. Therefore, all advertising material must be submitted to and approved by the Compliance Department prior to its printing or use.

Recruiting Advertisements

Recruiting advertisements include anything in a newspaper, magazine, newsletter, etc., which inform of an opportunity to represent the Company. All such advertisements must be submitted to Marketing Sales and approved by the Compliance Department prior to its use.

Testimonials/Claim Vouchers

Testimonials must be genuine, represent the current opinion of the author, be applicable to the policy being solicited and/or advertised. They must be accurately reproduced and be no more than 1 year old. Testimonials and/or Claim Checks can be used in the presentation and in advertising as long as certain regulatory requirements have been met and they have the Home Office Compliance Department’s prior approval in the form of a signed release statement.

Business Cards

Business cards are advertising and therefore fall within the guidelines and requirements of advertising regulations. Business cards that reference the Company, its logo or its products are to be printed only by the Home Office using the corporate format. A completed business card order form should be submitted to Marketing Services.

Training

All material used for training purposes must be reviewed and approved by the Compliance Department prior to its use. Training materials include, but are not limited to: video tapes, brochures, Product Information sheets, agent training guides, presentations, manuals, sales kits, and all printed training materials.

SOLICITATION

The primary purpose of life insurance is to protect the family. The agent’s job is to determine what products can best protect the family. To make this determination the agent will evaluate the customer’s life insurance needs, how the proposed insurance will fit into the customer’s existing coverage, and the customer’s ability to pay for the proposed life insurance coverage. The agent must clearly explain the product in full. This includes identifying the product as “life insurance” and explaining all of the product’s benefits, exceptions, and limitations. The exceptions and limitations must be given the same amount of importance as the benefits. Using the approved advertising material provided by the Company will assist the agent in presenting the product accurately.

Presentations

Before the agent begins his/her sales presentation, he/she must first identify himself/herself as an insurance agent giving his/her full name and the complete name of the insurance company he/she represents, i.e. American-Amicable Life Insurance Company of Texas. When making the sales presentation, the agent must conduct himself/herself in an ethical and professional manner so as to not violate his/her state’s Unfair Trade Practices Act. The restrictions of this act include, but are not limited to, the following: �An agent cannot make any misrepresentative, misleading, false or deceptive statements, or act in any fraudulent or unethical manner.

	An agent cannot knowingly lead applicants to believe they will receive something other than life insurance. The agent must always identify the product as “life insurance.” He/she specifically cannot refer to the product as a “retirement plan”, “savings plan”, or “investment”.
	An agent cannot use words or phrases which exaggerate any benefits or limitations, exceptions or reductions of benefits.
	An agent cannot describe any policy provision or benefit without fairly and accurately describing all limitations, exceptions or reductions of benefits.
	An agent cannot use any insurance words, phrases or other terminology which might not be clearly understood by the applicant.
	An agent cannot identify himself/herself as an estate planner, financial planner, investment advisor or financial consultant, unless he/she is so licensed.
	An agent must explain that life insurance cost indexes are useful only for the comparison of the cost of two or more similar products.
	An agent cannot compare life insurance policies or cash values to savings, savings accounts, stocks, bonds or any other financial instrument or investment is such a way as may mislead a person as to the true nature of life insurance, surrender values, or other policy benefits.
	An agent cannot make any unfair or incomplete comparisons of other insurers, their policies, benefits, agents, services, method of marketing or compare unlike policies.
	An agent cannot make an impression to prospective insureds that the insurance product is endorsed, or accredited by any division or agency of the state or federal government. Products may, however, be offered or made available by an agency through payroll deduction.
	An agent cannot use terms such as “deposit”, “deposit premium”, “investment” or other such misleading or confusing terms, when referring to amounts which are in fact premiums for life insurance coverage.
	An agent cannot represent that the insurance product is an introductory, initial or special offer, or that applicants will receive substantial advantages given only to a specified group of individuals.
	An agent is prohibited from making any statement or implication to the effect that only a specific number of policies will be sold, or that it will be sold for a limited time period.
	An agent cannot present benefits showing guaranteed and nonguaranteed benefits as a single sum unless they are also shown separately in the same area of the presentation.
	An agent cannot use the existence of any state’s Guaranty Association for the purpose of inducing the purchase of insurance.

Suitability

The agent must ask the appropriate questions from the applicant to determine whether or not the sale of an insurance policy is suitable. The suitability of a recommended purchase is determined by reference to the totality of the customer’s circumstances, including, but not limited to, the customer’s income, the customer’s need for insurance, and the values, benefits and costs of the customer’s existing insurance program when compared to the values, benefits, and costs of the recommended policy. Determining suitability of a recommended sale is always vital, but it is especially so when dealing with the elderly.

Telemarketing

Telemarketing approaches are advertising and must follow the same approval process as any other advertisement. All telemarketing approaches, whether appointment generating only or solicitation calls, must by typed into a script and submitted to the Marketing Sales Department. Marketing will then work with the Compliance Department to obtain the required approval. Within the first 30 seconds, the telemarketing script must:

1. identify the caller by first and last name;

2. identify the specific insurance carrier the caller represents;

3. state the purpose of the call; and

4. identify the specific type of insurance for which the call was made.

Some states allow lead/appointment generation by nonlicensed individuals. However, all solicitations by phone must be handled by licensed agents. Solicitation includes any description of the policy benefits, policy terms, premium amounts, etc.

Prohibition of Deceptive and Abusive Telemarketing Acts

The federal government has enacted laws to prohibit deceptive and abusive telemarketing. In order to comply, the following telemarketing requirements must always be observed:

1. No calls should be made before 8:00 a.m. or after 9:00 p.m. local time for the receiver.

2. No second call shall be made to a prospect if that prospect so requests.

3. No unsolicited faxes may be sent. You may fax requested information to a prospect you have already spoken with, but you cannot use the fax to send unrequested material.

4. Autodialers may not be used without Home Office Compliance Department approval.

Churning

Churning is a prohibited act which violates the states’ Unfair Trade Practices Acts. Churning is defined as the practice whereby policy values (cash, loan, dividend values, etc.) in an existing life insurance policy or annuity contract are utilized to purchase another insurance policy or annuity contract with the same insurer or group of insurers for the purpose of earning additional premiums, fees, commissions, or other compensation:

1. Without an objectively reasonable basis for believing that the replacement will result in an actual and demonstrable benefit to the policyholder;

2. In a fashion that is fraudulent, deceptive, or otherwise misleading; or

3. In a fashion that involves a deceptive omission;

a) Such as not informing the applicant that the policy values, including cash values, dividends, and other assets of the existing policy or contract will be reduced, forfeited, or utilized in the purchase of the replacing or additional policy; or

b) Such as not informing the applicant that the replacing or additional policy will not be a paid-up policy or that additional premiums will be due, if this is the case. The purchase must always be in the customer’s best interest. Any insurance sale must pass the suitability test whereby it is in the best interest of the applicant to purchase the insurance when taking into account his/her income and existing coverage.

Replacement Requirements

Replacement means that an existing life insurance policy or annuity contract will be surrendered, lapsed, placed on a paid-up basis, borrowed against, placed on extended term insurance, or otherwise reduced in value in order to purchase the coverage for which the application is being taken. Be sure to ask all relevant questions on the application to determine if replacement is involved. If yes, provide any necessary replacement notices in order to meet state disclosure requirements.

Agents must comply with all Company procedures regarding replacement. Internal replacements are monitored very closely by the Home Office to insure the proposed coverage represents an overall improvement in the policyholder’s coverage.

Twisting

Twisting is strictly prohibited in all states. Twisting is the practice of misrepresenting a policy or misstating the facts or giving an incomplete comparison of policies to induce the insured to give up a policy in one company for the purpose of taking insurance in another. It is prohibited for agents to make misleading, derogatory, false or maliciously critical statements about the financial condition of an insurance company. This includes repeating market rumors or circulating news articles questioning a competitor’s solvency.

Misrepresenting “Vanishing Premiums”

Class actions have been brought against companies whose agents misrepresented the premium payment schedule for insurance products. Terms such as “single payment” or “vanishing premiums” do not accurately describe how the insurance products work. Since these products are interest sensitive, there is no way to know if additional premiums will be required in the future. We do not market any single premium product and agents cannot describe the option of using accumulated cash values to pay the premiums as “vanishing premiums”. They must completely explain the advertising material, pointing out that illustrations are based on current interest rates that may vary in the future and affect their premium payment schedule. Explain that the Company will give them timely notice if additional premium payments are required.

Disparaging Comments About Competitors

It is a violation of the Unfair and Deceptive Trade Practices Act to make disparaging, false or misleading statements about competitors. An agent cannot make any unfair or incomplete comparisons with other insurers, their policies, benefits, agents, services, method of marketing or compare unlike policies. This includes repeating market rumors or circulating news articles questioning a competitor’s solvency. Violations can result in the revocation or suspension of an agent’s license and are subject to large fines per occurrence.

GENERAL MILITARY PROHIBITED PRACTICES

I. Department of Defense Directive 1344.7

The following commercial solicitation practices shall be prohibited on all DoD installations:

a. Solicitation of recruits, trainees, and transient personnel in a “mass” or “captive” audience.

b. Making appointments with or soliciting military personnel who are in an “on-duty” status.

c. Soliciting without appointment in areas utilized for the housing or processing of transient personnel, in barracks areas used as quarters, in unit areas, in family quarters areas, and in areas provided by installation commanders for interviews by appointment.

d. Use of official identification cards by retired or reserve members of the Military Services to gain access to DoD installations for the purpose of soliciting.

e. Procuring, or attempting to procure, or supplying roster listings of DoD personnel for purposes of commercial solicitation, except for releases granted in accordance with DoD Directive 5400.7 (reference (c)).

f. Offering unfair, improper, and deceptive inducements to purchase or trade.

g. Using rebates to facilitate transactions or to eliminate competition.

h. Using manipulative, deceptive, or fraudulent devices, schemes, or artifices, including misleading advertising and sales literature.

i. Using oral or written representations to suggest or give the appearance that the Department of Defense sponsors or endorses any particular company, its agents, or the goods, services, and commodities it sells.

j. Full-time DoD personnel making personal commercial solicitations or sales to DoD personnel who are junior in rank or grade as provided in DoD Directive 5500.7 (reference (d)).

k. Entering into any unauthorized or restricted area.

l. Using any portion of installation facilities, including quarters, as a showroom or store for the sale of goods or services, except as specifically authorized by DoD Directives 1330.9 and 1330.17 and DoD Instructions 1330.18 and 1000.15 (references (e), (f), (g), and (h)). This is not intended to preclude normal home enterprises, providing applicable state and local laws are complied with.

m. Soliciting door to door.

n. Advertising addresses or telephone numbers of commercial sales activities conducted on the installation.

II. Department of Army Directive 210-7

Forbidden solicitation practices. Installation commanders will prohibit the following:

a. Solicitation during enlistment or induction processing or during basic combat training, and within the first half of the one station unit training cycle.

b. Solicitation of “mass”, group, or “captive” audiences.

c. Making appointments with or soliciting of military personnel who are in an “on-duty” status.

d. Soliciting without an appointment in areas used for housing or processing transient personnel, or soliciting in barracks areas used as quarters.

e. Use of official identification cards by retired or Reserve members of the Armed Forces to gain access to military installations to solicit.

f. Offering of false, unfair, improper, or deceptive inducements to purchase or trade.

g. Offering rebates to promote transaction or to eliminate competition. (Credit union interest refunds to borrowers are not considered a prohibited rebate.)

h. Use of any manipulative, deceptive, or fraudulent device, scheme, or artifice, including misleading advertising and sales literature.

i. Any oral or written representations which suggest or appear that the Department of the Army sponsors or endorses the company or its agents, or the goods, services, and commodities offered for sale.

j. Commercial solicitation by an active duty member of the Armed Forces of another member who is junior in rank or grade, at any time, on or off the military installation (AR 600-50).

k. Entry into any unauthorized or restricted area.

l. Assignment of desk space for interviews, except for specific, prearranged appointments. During appointments, the agent must not display desk or other signs announcing the name of the company or product affiliation.

m. Use of the “Daily Bulletin” or any other notice, official or unofficial, announcing the presence of an agent and his availability.

n. Distribution of literature other than to the person being interviewed. o. Wearing of name tags that include the name of the company or product that the agent represents.

p. Offering of financial benefit or other valuable or desirable favors to military or civilian personnel to help or encourage sales transactions. This does not include advertising material for prospective purchasers (such as pens, pencils, wallets, and notebooks, normally with a value of $1 or less).

q. Use of any portion of installation facilities, to include quarters, as a showroom or store for the sale of goods or services, except as specifically authorized by regulations governing the operations of exchanges, commissaries, non-appropriated fund instrumentalities, and private organizations. This is not intended to preclude normal home enterprises, providing State and local laws are complied with.

r. Advertisements citing addresses or telephone numbers of commercial sales activities conducted on the installation.

III. Department of the Navy Directive SECNAVINST 1740.2D

Prohibited Solicitation Practices

a. Solicitation of recruits, trainees, and other personnel while in a “mass” or “captive” audience onboard an installation.

b. Making appointments with or soliciting military personnel who are in an “on-duty” status.

d. Use of official identification cards, vehicle stickers or passes by retired or reserve members of the armed forces to gain access to installations for the purpose of soliciting.

e. Procuring or supplying, or attempting to procure or supply roster listings of DON personnel for the purpose of commercial solicitation, except pursuant to procedures implementing the Freedom of Information Act.

f. The offering of unfair, improper or deceptive inducements to purchase or trade.

g. Practices involving rebates to facilitate transactions or to eliminate competition. (Credit union interest refunds to borrowers are not considered a prohibited rebate.)

h. The use of any manipulative, deceptive or fraudulent device, scheme or artifice, including misleading advertising and sales literature.

i. Using oral or written representations to suggest or give the appearance that DoD or DON sponsors or endorses any particular company, its agents, or the goods, services and commodities it sells.

j. The entry into any unauthorized or restricted area.

k. Solicitation by a military member of another military member who is junior in rank or grade, whether on or off duty, in or out of uniform, on or off a military installation at any time, except as permitted in subparagraph 6e of SECNAVINST 5370.2H, Standards of Conduct and Government Ethics.

l. Using any portion of installation facilities, including quarters, as a showroom or store for the sale of goods or services, except as specifically authorized by regulations governing the operation of exchanges, commissaries, non-appropriated fund instrumentalities, and private organizations. This is not intended to preclude private home enterprise sales authorized under paragraph 13 of the basic instruction.

m. Soliciting door to door.

n. Advertising addresses or telephone numbers of commercial sales activities conducted on the installations, except for authorized activities conducted by members of military families residing in family housing.

o. DoD personnel representing an insurance company, or dealing directly or indirectly with any insurance company or any recognized representative of an insurance company as an agent, or in any official or business capacity, for the solicitation of insurance to personnel on a military installation.

p. Agents assuming or using titles such as “Battalion Insurance Counselor”, “Unit Insurance Advisor”, “SGLI Conversion Consultant”, etc., which can give rise to an inference of government or unit approval.

q. The assignment or use of office or desk space for an interview for other than a specified, prearranged appointment. During prearranged appointments, the agent will not display desk or other signs announcing name or company affiliation.

r. The use of base bulletins, the plan of the day, or any other notice, official or unofficial announcing the presence of an agent and his or her availability.

s. The distribution, or availability for distribution, of literature or advertisement materials other than to the person being interviewed.

IV. Department of Air Force – Utilizes DoD Directive 1344.7 exclusively.

While the above reflects “Prohibited Practices”, you should also read the actual regulation in its entirety. A complete copy of the applicable Department of Defense, Department of Army, and/or Department of Navy regulation/instruction and any local regulations are in your area office with the General Agent. You must read, understand, and follow all these regulations/instructions.

Additionally, you are required to comply with any individual post or base supplements to the above regulations that affect your particular area of operation.

DID YOU REMEMBER TO SIGN AND DATE THE COMPLIANCE POLICY STATEMENT OF UNDERSTANDING LOCATED AT THE BEGINNING OF THIS MANUAL? (REQUIRED FOR CONTRACTING)