Collecting information about non-owner payors of insurance policies

As an advisor, you play a key role in helping us remain compliant with Anti-Money Laundering (AML). For insurance policies, that means collecting information from individuals, including family members and spouses, who pay for an insurance policy but aren’t the owner. We’ll collect the required information for new policies, but we’re asking for your help to collect the required information on historical policies where we may have missed it in the past.  We need to collect the following information:

  • individual payor: name, date of birth, occupation, relationship to policy owner, residential address and phone number.  

  • entity payor:  corporation name, corporation number, country and province/state of registration, detailed principal business, relationship to policy owner, business address and phone number.  

Starting October 27, 2020, we’ll send notifications in secure Activity Centre to advisors with in-force permanent and universal life insurance policies with missing information about non-owner payors.  We’ll ask you to contact these Clients and share a Third Party Determination form (4557) to complete and return to Sun Life. If we don’t hear back from a Client after 20 days, we’ll send a reminder to the advisor to follow up. If we still don’t hear back from the Client, we’ll assess the risk of not collecting the AML information and determine if further action is required.

Client messaging

When you receive the notice from us, please contact the Client and share the form with them. You can use the wording below to help create your message to the Client:

  • We noticed you have someone paying for your life insurance policy.
  • Because of this, we need to collect some additional information from you.
  • We’re collecting this information to ensure we follow regulatory requirements about insurance policies that are paid for by someone who isn’t the owner of the policy.
  • Could you please complete this form and return it to Sun Life or to me.
  • You can:
    • mail the form to:

      Sun Life Assurance Company of Canada
      P.O. Box 1601 STN Waterloo
      Waterloo, ON N2J 4C5

    • fax the form to 1-866-487-4745
    • upload the completed form to the Sun Life mobile app
  • If you have any questions or would like to talk, please call me at PHONE NUMBER, or you can call Sun Life at 1-877-786-5433.
Questions and answers

Q. Does the Client need to mail the form to Sun Life?  
A. The Client can send the completed form to Sun Life by mail, DDE (digital document exchange) on the Sun Life mobile app, or by fax.

Mailing address:
Sun Life Assurance Company of Canada
P.O. Box 1601 STN Waterloo
Waterloo, ON N2J 4C5

Fax number: 1-866-487-4745


Q.  The Client sent the completed form to me. Where should I send it?
A.  You can send the form to us through Request Centre, by fax, or mail.

Q. Do I need to meet with the Client in person?
A. No. You can send the form to the Client to complete. Alternatively, you may want to use this as an opportunity to check in with the Client.

Q.  What happens if the Client doesn’t complete the form?
A: If we don’t hear back from the Client after 20 days, we’ll send a reminder to the advisor to follow up. If we still don’t hear back from the Client, we’ll assess the risk of not collecting the AML information and determine if further action is required.   

Q. Why is the Client receiving this now when the policy has been in force for so many years?
A. Sun Life needs to collect this information as part of its Anti-Money Laundering (AML) obligations where we may have missed it in the past.

Q. What if the client lives out of country and I’m the advisor of record?
A. You can still send the Client the form to complete and return to Sun Life.