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I didn't want to kill ROP. But I'll try to explain "their" logic - ROP is not life insurance. It's a gimmick.
Actuarially, I know it's a gimmick. You simply charge extra for the ROP. But this is government substituting its wisdom for that of consumers.
Well it is certainly NOT a gimmick. It is taking advantage of the tax treatment of life insurance cash values and extending that benefit to a term life insurance product.
Whole life guys hate it because it means an alternative to the whole life versus term argument, where term is no good because you dont' get any money back. Of course that argument was always BS because inside EVERY life insurance policy is a mortality element where you never get your money back unless you die. The only thing that ever creates excess money is excess money plus a return on investment.
So ROP gives people their money back at a much lower premium than whole life, and the whole life guys are now whining about it. No doubt they were the one's pushing regulators to toughen up.
Personally there is only one reason to buy whole life insurance and that is for the death benefit and the ability to have it in force for the whole of your life, something term can't do and wasn't intended to do.