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What Critics Get Right

Nine arguments are made against this approach. Five are conceded outright, three are partly correct with a stated limit, and one is rejected because it applies American tax rules that have no Canadian counterpart. This page states each argument in its strongest form before answering it, and where an argument holds it is not answered at all.

1. The comparison is made against the wrong alternative. 1. The argument. Supporters compare a policy loan to borrowing from an outside lender and conclude the policyowner keeps interest that ... 2. Verdict: conceded. This is the strongest criticism in the field and it is correct. Set out in full on the comparison question . 3. The argument. Presentations imply that interest paid on a policy loan returns to the owner. It does not. It is paid to the insurer. 4. Verdict: conceded. Any presentation implying dollar-for-dollar recovery is describing something that does not happen. 5. The argument. A fund publishes a management expense ratio: one number, standardised, comparable. A participating contract publishes ... 6. Verdict: conceded. Discussed, along with how to measure the cost anyway, on the real costs .

Nine arguments are made against this approach with any regularity. Each is set out below in the form a serious critic would make it, followed by a verdict.

The verdicts are not evenly distributed. Five are conceded outright. Where an argument is conceded, nothing follows it, because a concession with a rebuttal attached is not a concession.

1. The comparison is made against the wrong alternative

The argument. Supporters compare a policy loan to borrowing from an outside lender and conclude the policyowner keeps interest that would otherwise have left. But most people were never going to borrow. They were going to pay from savings, and savings cost no interest at all.

Verdict: conceded. This is the strongest criticism in the field and it is correct. Set out in full on the comparison question.

2. Interest on a policy loan is not recovered by the policyowner

The argument. Presentations imply that interest paid on a policy loan returns to the owner. It does not. It is paid to the insurer.

Verdict: conceded. Any presentation implying dollar-for-dollar recovery is describing something that does not happen.

3. The costs are not disclosed the way a fund's are

The argument. A fund publishes a management expense ratio: one number, standardised, comparable. A participating contract publishes nothing equivalent. The mortality charge, the expense loading and the compensation are absorbed inside the contract and never itemised for the buyer.

Verdict: conceded. Discussed, along with how to measure the cost anyway, on the real costs.

4. The cost is front-loaded and the buyer carries the exit risk

The argument. Compensation and acquisition expense fall heaviest in the first years, which is exactly when a buyer is most likely to change their mind. The structure places the cost of an early exit on the person least equipped to price it.

Verdict: conceded.

Which of these applies to what you were shown? Button: Start a conversation.

5. Most people should use registered contribution room first

The argument. For a majority of Canadian households, unused TFSA or RRSP room is the better home for surplus money, and it should be used before a permanent insurance contract is considered for this purpose.

Verdict: conceded, with the target named precisely. The criticism lands squarely against substitution: a household persuaded to fund a permanent contract instead of registered room it has not used, for accumulation purposes. That is a mis-sale and it happens.

Where it lands less cleanly is against the method itself, which does not propose substitution. Registered plans keep their purpose and their contributions and are funded from within the household's flow rather than in competition with it. A household that stops funding registered plans because it arranged a contract has misunderstood both, and so has an advisor who encouraged it.

What survives the distinction. Any presentation that does not establish whether registered room is being displaced is incomplete, and the question should be asked before a contract is discussed rather than after.

6. The terminology overstates what the owner controls

The argument, in the critics' own words. The phrase becoming your own banker, taken from the title of Nelson Nash's book and a registered trademark of Infinite Banking Concepts, LLC, promises something a contract cannot deliver.

Language in this field implies operating an institution and independence from the financial system. What is owned is a contract with an insurer, administered by the insurer under its terms.

Verdict: partly conceded. The criticism of the language is correct and the marketing in this field earns it. The limit is that the underlying feature is real: a contract does permit the owner to request a loan against value without a credit assessment, on terms fixed by the contract rather than by a lender's appetite that year. That is a genuine difference in access. It is not independence, and it should not be described as if it were.

7. Illustrations are treated as forecasts

The argument. A document showing values decades out is arithmetic under assumptions. Dividend scales move. Presenting a projection as an expectation misleads whether or not anyone intends it.

Verdict: partly conceded. The misuse is real and common. The limit is that an illustration also contains a guaranteed column, which is contractual and does not depend on any assumption. The failure is in showing only the illustrated column, not in the existence of illustrations. Ask for both.

8. Policies are sold to people who should not have them

The argument. Compensation is paid at issue while suitability depends on decades of stable cash flow. Those two facts create pressure in one direction.

Verdict: partly conceded. The incentive is real and is disclosed on the author page. The limit is that the same structure exists across advised financial products, and the answer is a suitability test the buyer can apply themselves, which is why the failure modes names who carries the most risk rather than leaving it general.

Did anyone concede anything? Button: Start a conversation.

9. The tax advantages are overstated

The argument. Most versions of this argument come from the United States and reason from the modified endowment contract rules, or from section 7702 of the US Internal Revenue Code, to conclude that the tax treatment is narrower than claimed.

Verdict: rejected, for Canada. Not because the caution is unwarranted, but because those rules do not govern a Canadian contract. The Canadian test is whether a contract remains exempt under Regulation 306, Income Tax Regulations, and a policy loan is a disposition under ITA s.148(9). A Canadian reader applying the American analysis is being warned about rules that do not apply and reassured about none of the rules that do.

This is the one place where imported criticism genuinely misleads, and it misleads in both directions.

What the tally means

Five conceded, three partly conceded, one rejected on jurisdiction.

That is not a defence of the product. It is a narrower claim: the product is narrower than its marketing suggests, suits fewer people than are shown it, and is criticised most effectively by people who have understood it. A reader who has absorbed all nine arguments is better placed to evaluate a presentation than one who has only heard the case in favour.

A participating whole life contract is an insurance product and it is not an investment. Most of the criticism above is what happens when it is sold as something else.

Three arguments that are made and are simply wrong

Included because a page claiming to weigh criticism honestly has to say where the criticism fails, not only where it lands.

"It is a scam." No recruitment structure, no return funded by later entrants, no unregistered instrument. A participating contract is issued by a supervised insurer under provincial legislation with terms in a document you read before signing. The word describes fraud, and applying it to a regulated contract makes the genuine criticisms easier to dismiss.

"The insurance company keeps your cash value when you die." Stated frequently and it misdescribes the arrangement. What is paid on death is the death benefit, which is larger than the cash value in any ordinary contract. The cash value is not a separate account withheld; it is a value within the same contract the benefit is paid under. The contract settles it at maturity: a policy written to age 100 endows there, and in the guaranteed column the cash value and the death benefit at age 100 are the same figure. They converge because they were always converging on the same thing, and an illustration truncated before maturity removes the row that proves it. Whether the total is good value is a fair question. This particular framing is not.

"You can do better with buy term and invest the difference." Sometimes true, and stated as a universal it assumes the difference is actually invested, that it stays invested through a downturn, that the term coverage is replaced when it expires, and that the person remains insurable. Those four assumptions frequently fail, and a comparison assuming all four holds is comparing a disciplined ideal against a real product.

Why saying this matters. A page that concedes everything is not more honest than one that concedes nothing; it is simply less useful. The nine arguments above are conceded or partly conceded because they are correct, and these three are rejected because they are not.

What a critic and a practitioner would both agree on

A shorter list than either side admits, and worth stating because it is where a reader can stand.

The costs are front-loaded and early exit is expensive. Dividends are not guaranteed. Most households should use registered contribution room first. Illustrations are projections and are routinely misused. The product requires a horizon measured in decades. And it is sold to people who should not have it.

Six statements, all agreed on both sides. A reader who holds only those is better equipped than one who has read either side's full case, and that is an uncomfortable thing for a practice to publish.

Would this description survive a sceptical reading? Button: Start a conversation.

Why a practice publishes a list of concessions

Nine criticisms, most conceded, on a site belonging to a practice that places these contracts. The reason should be stated rather than left to be inferred.

Because they are true. A page omitting them is inaccurate by silence, which is the same failure as inaccuracy by statement and harder to detect.

Because the reader will meet them anyway, usually presented at their strongest by someone with the opposite commercial interest, and without the three that are wrong separated out. Meeting them here first is better for the reader.

Because a practice unwilling to state them has told you what its description of the benefits is worth. A description that concedes nothing is advertising whatever its tone.

And because the criticisms are the specification. Read carefully, this page is a list of the ways this product is mis-sold: the wrong comparison, the undisclosed cost, the front-loaded exit risk, the displaced registered room, the overstated terminology, the illustration read as a forecast, the unsuitable buyer. A practice that avoids all nine is doing the job properly, and a reader holding the list can check whether it has.

How to use this list when somebody is selling to you

Ask which of the nine applies to what you are being shown. An honest answer names at least one, because at least one always applies.

Ask for the guaranteed column, which answers points 3, 4 and 7 at once.

Ask whether registered room is being displaced, which answers point 5.

Ask what the interest on an advance does and where it goes, which answers point 2 and separates a practitioner who understands the mechanics from one repeating a phrase.

Ask who should not buy this, which answers point 8. An honest answer arrives quickly and names categories.

Five questions. None requires technical knowledge, all are answerable from the contract and the illustration, and the reaction to them is as informative as the answers.

What none of the nine establishes

Worth stating, because a list of concessions can be read as a verdict and it is not one.

None of them shows the product does not work. They show it is expensive as a growth vehicle, unforgiving of early exit, opaque on cost, and frequently mis-sold. A product can be all four and still be right for a particular household, which is what suitability means.

None of them addresses the death benefit, which is the thing actually being bought and which no portfolio provides.

And none of them is an argument about you. Every criticism here is general. Whether any applies to your situation depends on facts this page does not have, and that is the question the criticisms exist to help you ask rather than answer.

What a practitioner would concede in private

Worth writing down, because these are the things said in advisor conversations and rarely in marketing.

The first-year numbers are hard to defend to a new client, and every practitioner knows it. The usual response is to direct attention to year twenty.

Most illustrations are shown at the current scale only, because the lower scenario is less persuasive, even though the insurer prints it as standard.

A meaningful share of contracts written do not survive ten years, and the households that surrender are worse off than if nothing had been arranged.

Compensation weighted to the first year shapes behaviour, and pretending it does not is the least credible thing this industry says.

None of that makes the product wrong. It makes the distribution the weak point, which is what the eighth criticism above already says and which practitioners generally accept privately.

What this list is for

Not to talk you out of the product. Five of the criticisms stand and the product still suits some households.

To let you test what you are shown. Each item is a way this product is mis-sold, and a presentation avoiding all nine is doing the job properly.

And to make the concessions before somebody else does, because a criticism first met from a competitor lands harder than one already conceded.

What to do with this page

Take it into the next conversation.

Ask which of the nine applies. Ask for the guaranteed column. Ask who should not buy it. The answers, and the willingness to give them, tell you more than any illustration.

And notice what happens when you ask. A practitioner who concedes readily is describing a product. One who concedes nothing is selling one, and the difference is audible within a minute of asking.

The willingness to concede is the signal. Not because concession proves competence, but because a description that admits its own weaknesses has told you what it is, and one that admits none has told you what it is doing. Both are informative and only one is useful, and you can establish which within the first few minutes of any conversation about this product.

Ask early. The concession, or its absence, arrives in the first few minutes and costs nothing to find out. A conversation that begins with what the product does badly is one that can be trusted about what it does well.

It is the cheapest diligence available anywhere in this subject.

What this page will not do

It will not use a list of concessions as a credibility device and then arrive at a recommendation.

Publishing criticism is a well-known way to appear trustworthy immediately before asking for something. This page ends here, with no next step and no invitation, because a page whose entire purpose is honesty about the arguments against should not close by selling.

A thirty-minute discovery meeting

A first conversation establishes whether this fits. No illustration is prepared and nothing is arranged.

Often the answer is no, and you will hear it during the call rather than in a proposal afterwards.

Hold a licence? To place business, deal directly with Canadian Wealth Creation Centre Inc. This page is for households.

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This form reaches Canadian Wealth Creation Centre Inc. Any meeting, any advice and any insurance product is provided by Canadian Wealth Creation Centre Inc., through its representatives certified by the Autorité des marchés financiers. IBC Financial is the company's education platform: it distributes no product and no financial service, and it gives no individualised advice.

Important disclosure

Common questions

How many of the standard criticisms are correct?

Five of the nine are conceded outright: the comparison is made against the wrong alternative, interest on an advance is not recovered by the owner, the costs are not disclosed the way a fund's are, the cost is front-loaded so the buyer carries the exit risk, and most households should use registered contribution room first. Three are partly correct with the limit stated: the terminology overstates control, illustrations get treated as forecasts, and policies are sold to people who should not have them. One is rejected, and only because it reasons from American tax rules that do not govern a Canadian contract.

What would a practitioner concede in private?

Most of what is on this page, and usually more readily than in a presentation. That the early years feel like nothing is happening, and that the guaranteed column at year three is lower than a buyer expects. That the majority of households should not do this. That the language used across this field is overstated and earns the criticism it attracts. That an illustration showing a constant dividend scale for thirty years is showing an assumption. And that compensation paid at issue sits uncomfortably beside a product needing decades of stable funding. Publishing those admissions rather than reserving them for private conversation is the point of the page.

Which criticism is the strongest?

That the comparison usually offered is against the wrong alternative. The standard case sets an advance against borrowing from an outside lender and concludes the owner keeps interest that would otherwise have left. Most households were never going to borrow for that purchase; they were going to pay from savings, which costs no interest at all. Measured against savings the advantage shrinks considerably and can disappear. It is conceded here rather than answered, and it has a page of its own. Any presentation that does not name which alternative it is comparing against has left out the variable that decides the result.

Does conceding these arguments mean the product is a bad one?

No, and conflating those two findings is its own error. What the concessions establish is that the product is narrower than its marketing suggests and suits fewer households than are shown it: it needs surplus cash flow that survives a poor decade, a horizon measured in decades, and a genuine want for permanent coverage. That is a suitability conclusion rather than a verdict on the contract. A page that concedes everything is not more honest than one that concedes nothing; it is simply less useful. Three commonly made criticisms are rejected on this page precisely because they are inaccurate.

Is buy term and invest the difference better?

Sometimes, and stated as a universal it assumes four things that frequently fail. That the difference is actually invested rather than spent. That it stays invested through a downturn. That the term coverage is replaced when it expires, at the older age and the higher price. And that the person is still insurable when that time comes. Where all four hold, the comparison usually favours term plus a portfolio, and saying so is the honest position. Where the need for coverage is genuinely permanent and the discipline is not certain, the comparison is between a plan and a product rather than between two products.

Do critics and practitioners agree on anything?

More than either side admits, and the shared ground is where a reader can stand. Both accept that the costs are front-loaded and early exit is expensive, that dividends are not guaranteed, that most households should use registered contribution room first, that illustrations are projections and are routinely misused, that the product requires a horizon measured in decades, and that it is sold to people who should not have it. Six statements, agreed on both sides. A reader holding those six is well equipped to weigh anything either side says next, and publishing them is the most useful thing this practice can do before a first conversation.

Who makes these criticisms, and does the source matter?

The source is worth knowing and it settles nothing. Some criticism comes from people who sell competing products and have a commercial interest in the conclusion. Some comes from independent analysts with no stake at all. Some comes from households who bought a contract, were disappointed, and are describing a real experience accurately. An argument is not weakened by who makes it, and it is not strengthened either. Test each one against the contract, the statute or the arithmetic instead. The same test applies to this page, which is published by a practice paid by commission when a contract is issued.

Is the commission a conflict of interest?

Yes, and stating it plainly is more useful than explaining it away. Compensation is paid when a contract is issued, while suitability depends on funding sustained for decades, and those two facts create pressure in one direction. The limit on the criticism is that the same structure exists across advised insurance products in Canada, which is a description of the market rather than a defence. What a buyer can do about it is apply the suitability test themselves: ask who should not do this, ask what the guaranteed column shows at year three, and ask what the person is paid and when.

Are illustrations forecasts?

No, and treating them as forecasts is one of the commonest failures in this field. An illustration is arithmetic performed under stated assumptions, chief among them a dividend scale the insurer can change and historically has changed in both directions. What it also contains is a guaranteed column, which is contractual and depends on no assumption at all. The failure is in showing only the illustrated column, not in the existence of illustrations. Ask for both, compare them at years three, five and ten, and treat the gap between them as the measure of how much of the picture is assumption.

Does this approach tell people to skip their RRSP or TFSA?

It should not, and where it does the criticism lands squarely. The mis-sale being described is substitution: a household persuaded to fund a permanent contract instead of registered room it has not used, for accumulation purposes. That happens, and it is a mis-sale. The method itself does not propose substitution; registered plans keep their purpose and their contributions, funded from within the household's flow rather than in competition with it. What survives the distinction is that any presentation which does not establish whether registered room is being displaced is incomplete, and the question belongs before a contract is discussed rather than after.

Are the tax advantages overstated?

In the United States that argument has force. Applied to a Canadian contract it misleads in both directions. Most versions reason from the American modified endowment contract rules or from section 7702 of the US Internal Revenue Code, neither of which governs anything here. The Canadian tests are different: a contract must remain exempt under Regulation 306 of the Income Tax Regulations, and an advance is a disposition under section 148 of the Income Tax Act, with amounts above the adjusted cost basis capable of being taxable. A Canadian reader taking the imported critique at face value is warned about rules that do not apply and reassured about none of the rules that do.

Is the criticism of the terminology fair?

Largely yes, and it is conceded here. The phrase taken from the title of Nelson Nash's book, a registered trademark of Infinite Banking Concepts, LLC, promises more than a contract can deliver, and language across this field implies operating an institution and standing outside the financial system. What is owned is a contract with an insurer, administered by the insurer under its terms. The limit on the criticism is that the underlying feature is real: the contract permits an advance against value without a credit assessment, on terms fixed at issue rather than by a lender's appetite in a given year. That is a genuine difference in access, and it is not independence.

How should I use this list when somebody is selling to me?

Take it with you, including to a conversation with this practice. Ask which of the nine arguments the person has met before and what they make of each. Somebody who has genuinely understood the product can state the concessions without prompting and without irritation. Ask specifically about the comparison: which alternative are you measuring this against, and what happens to the case if the household would have paid cash. Then ask who should not do this. The answers matter, and a description that can carry its own strongest objections is the one worth trusting, which is why those objections are published here in full.

Sources

  • Income Tax Regulations, Regulation 306, Justice Laws Canada, verified 2026-08-21
  • Income Tax Act s.148(9), Justice Laws Canada, verified 2026-08-21

About the author

Last reviewed 2026-08-21. By Jose Salloum, Financial Security Advisor.

Important disclosures

Who you are dealing with. IBC Financial is the education platform and trade name of Canadian Wealth Creation Centre Inc. (cwcc.ca), the firm registered with the Autorité des marchés financiers. IBC Financial holds no licence, distributes no product or service, gives no individualised advice, and concludes no transaction. Every client relationship, every piece of advice and every insurance product comes only through Canadian Wealth Creation Centre Inc. and its duly certified representatives.

Licensing. Jose Salloum is a Financial Security Advisor (conseiller en sécurité financière) certified by the Autorité des marchés financiers in Quebec, a Life and Accident & Sickness Insurance Agent licensed by the Financial Services Regulatory Authority of Ontario, and a Life Insurance Agent licensed by the Insurance Council of British Columbia. Licensed since 2001. His personal licensing covers Quebec, Ontario and British Columbia only. He holds the Infinite Banking Concepts® Authorized Practitioner certification from the Nelson Nash Institute and the Certified Cash Flow Specialist designation. These are private certifications, not regulatory licences, and confer no government authority. All credentials may be verified in the regulators' public registers.

Protected titles. "Planificateur financier" is a protected title in Quebec, and "Financial Planner" and "Financial Advisor" are protected titles in Ontario. Jose Salloum does not hold or use these titles, and they are not used anywhere on this website.

Compensation and conflict of interest. As a licensed insurance professional, Jose Salloum receives commissions from insurers when a client purchases a policy. He is therefore not a neutral party. This website is the educational and marketing arm of Canadian Wealth Creation Centre Inc.

Nature of this website. This website is for general informational and educational purposes only. Nothing on it constitutes personalized financial, insurance, tax or legal advice, and reading it creates no professional-client relationship. Jose Salloum is not registered with the Canadian Investment Regulatory Organization and does not provide securities, tax or legal advice. Consult your own accountant and legal counsel before acting on anything described here.

About the products discussed. Participating whole life insurance is an insurance product, not an investment. Its primary purpose is the death benefit. Dividends are not guaranteed. They are declared annually at the discretion of the insurer's board of directors based on the performance of the participating account, and past dividend performance does not indicate future results. Contractual guarantees depend on the continued solvency of the issuing insurer and are not backed by any government. Policyholder protection in Canada is provided by Assuris, within its published limits. The Canada Deposit Insurance Corporation covers bank deposits and does not apply to insurance products. These strategies are not suitable for everyone and depend on individual circumstances, cash flow, time horizon and objectives.

Not a bank. Canadian Wealth Creation Centre Inc. and IBC Financial are not banks, are not deposit-taking institutions, and do not carry on banking business. Premiums paid into a policy are not deposits. Policy values are not deposits, are not held on deposit, and are not insured by the Canada Deposit Insurance Corporation.

Tax note. Tax treatment depends on the policy remaining exempt under Regulation 306 of the Income Tax Regulations and on your own circumstances. A policy loan is a disposition under ITA s.148(9). Amounts above the adjusted cost basis may be taxable, and if the policy lapses or is surrendered while a loan is outstanding, the gain becomes taxable in that year. Consult a qualified tax professional before acting.

Trademarks and affiliation. "The Infinite Banking Concept®" and "Becoming Your Own Banker®" are marks of Infinite Banking Concepts, LLC. Neither Canadian Wealth Creation Centre Inc. nor Jose Salloum is affiliated with, sponsored by, or endorsed by Infinite Banking Concepts, LLC or the Nelson Nash Institute. "Infinite Financial Sovereignty®" is a registered trademark of Jose Salloum, Canadian Intellectual Property Office registration TMA1420283, registered 12 June 2026. "IFS™" is used as an unregistered abbreviation of that mark.

Provincial variation. Insurance licensing titles and requirements vary by province and territory. Verify your own advisor's licensing with the regulator in your province.

Privacy Policy. Person responsible for the protection of personal information: Mona Haddad, info@cwcc.ca, Canadian Wealth Creation Centre Inc., 203-3899 Autoroute des Laurentides, Laval, QC H7L 3H7, 514-875-9444.