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Risk & Reward
Financing the Future
Laurence Neville
09/01/2004

It sounds too good to be true: a financial arrangement in which a loan funds the premium on a life insurance policy that, in turn, pays off the loan and also delivers a tax-free death benefit to our heirs. While some skeptical eyebrows have arched at what sounds like the financial equivalent of a perpetual motion machine, for some of us, under specific market conditions, these so-called premium finance transactions can make sense.

They are particularly useful for those with estate planning challenges stemming from having wealth locked in illiquid assets. Those who fear that their children will have to sell a precious asset—a family business or art collection, for example—to pay estate taxes can structure the premium financed insurance policy’s payoff to cover the estate tax.



The advantage of this approach over simply paying the premium is twofold. First, it frees up cash. This is important to those whose wealth is tied up in an illiquid or volatile asset (say, a family business or concentrated stock position). If we borrow to finance the insurance premium, we may free up millions of dollars in cash, which we can invest in assets that outperform those in the insurance policy. It also allows us to avoid gift taxes on the amount we would otherwise pay into a trust to fund an insurance policy’s premium.

Spreading Virtues
We typically secure a short-term loan to finance the premium in one of these transactions. These can range from one-year renewable loans to five-year facilities. They are often “pay-in-kind,” meaning the lender adds the interest charge to the principal each year. For example, a $100,000 loan with a 4 percent annual interest rate becomes a $104,000 loan the following year.



The cash value of the life insurance policy has to grow at a faster rate than the loan for these types of transactions to work. In the example above, the value of the insurance policy might grow by 6 percent. Since only part of the premium is credited to the insurance policy’s cash value when we first buy it (the rest compensates the insurance company for providing the insurance’s death benefit), the value has to grow faster than the loan to catch up and pass it in value, before the loan finally comes due.

Those who sell premium finance transactions say they are only available to those with investable assets over $5 million; they make most sense for those whose premiums will top $300,000 a year. They work best for those over 65 who expect to live long enough to build up enough cash value to pay off the loan; of course, the full benefit of this product only becomes apparent when we die, and our heirs enjoy a tax-free payout.

“Premium financing can be a wonderful strategy for the right client,” says Richard Wuensch, first vice president and estate planning specialist at Merrill Lynch in Houston. His colleague Andrew Bucklee, director of sales for life insurance distribution at Merrill Lynch in Hopewell, N.J., adds, “The exceptionally low interest rates of recent years have helped to raise its profile.” However, both caution that the financial logic of premium finance may change as rates rise.
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