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The Rule That Excuses a Trustee From Watching Your Life Insurance

Five investment duties can be switched off for a policy in trust. They are not off by default, and one beneficiary can switch them back on.

Section 736.0902 is the provision behind every irrevocable life insurance trust in Florida, and in sixteen years no court has said a word about it.

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Quick Overview

When the prudent investor rule does not apply

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Below, we walk through the 4 issues that decide whether this is the right move for you. Jump to any one.

  1. Six duties switched off From checking the insurer to diversifying the trust.
  2. Not automatic Five of the six apply only on an opt-in.
  3. A thirty day veto One written objection suspends them until withdrawn.
  4. Where it does not apply Affiliate policies, commissions, and no compensation.

That’s the quick version. The details below are what decide your situation, and where the costly mistakes hide.

Why this section exists

An irrevocable life insurance trust owns one asset, a policy. Judged as an investment portfolio, that is a spectacularly imprudent arrangement. It is undiversified, it produces no income, and it pays nothing until someone dies.

Florida’s prudent investor law, which the Trust Code imports wholesale through section 736.0901 and reinforces in section 736.0804, would ordinarily require a trustee to diversify, monitor and reconsider. This section removes that problem by removing the duties.

Six of them, and they are listed. With respect to a policy on the life of a qualified person, a trustee has no duty to determine whether the policy complied with the insurable interest statute, to determine whether it is or remains a proper investment, to investigate the insurer’s financial strength, to determine whether to exercise any policy option, to diversify the policy or the trust’s assets in relation to it, or to inquire about the health or financial condition of any insured.

Subsection (3) completes the picture. The trustee is not liable to the beneficiaries or anyone else for loss sustained with respect to a policy this section covers.

The part almost everyone gets wrong

The safe harbour is not one switch. It is two, and only one of them is on by default.

Paragraph (1)(a), the insurable interest question, applies automatically to any policy on a qualified person unless the trust says otherwise.

Paragraphs (1)(b) through (f), which are the five that matter in practice, apply only if one of two things has happened.

(a) The trust instrument, by reference to this section, makes this section applicable to contracts for life insurance held by the trust; or

(b) The trustee gives notice that this section applies to a contract for life insurance held by the trust.

Section 736.0902(5), Florida Statutes.

So a trustee holding a policy under a trust drafted without reference to this section, who has never given notice, still owes all five duties. They must consider whether the policy remains appropriate, check the insurer, weigh the options, and so on. The protection people assume applies to every life insurance trust in Florida applies only where somebody took a step.

If you are a trustee in that position, this is the most useful thing on this page. If you are a beneficiary wondering whether anyone was supposed to be watching, it is the first question to ask.

The notice, and the thirty day veto

The notice route has conditions. The notice goes to the qualified beneficiaries, and it must contain a copy or restatement of the section itself, so the recipients can see what is being switched off. It may be given to a representative under Part III instead, and it must be given in the manner set out in section 736.0109.

Then comes the part that gives a beneficiary real leverage.

If any person notified pursuant to this paragraph delivers a written objection to the application of this section to the trustee within 30 days after the date on which the objector received such notice, paragraphs (1)(b)-(f) shall not apply until the objection is withdrawn.

Section 736.0902(5)(b)4, Florida Statutes.

One objection, from one person, in writing, within thirty days. That is the whole requirement, and the effect lasts until the objection is withdrawn. Not until a court says otherwise, and not until the trustee overrules it. The duties stay on.

There is also a mailing rule. Notice sent by United States mail is presumed received three days after it goes into the mail, and the presumption is rebuttable. That matters, because the thirty days runs from receipt.

The three limits on the trustee’s side

The Legislature built in protections against the obvious abuse, which is a trustee who sells the policy, takes the commission, and then disclaims responsibility for it.

Affiliates and commissions. The section does not apply at all to a policy purchased from an affiliate of the trustee, or one on which the trustee or an affiliate receives any commission, unless the duties were delegated to another person under section 518.112. Affiliate is defined in the subsection as anyone who controls, is controlled by, or is under common control with the trustee.

No compensation. Subsection (8) says a trustee performing services related to a policy covered by subsection (1) may not be compensated for performing that service. You are not paid for a duty you do not owe.

The insurable interest carve out. Paragraph (1)(a) does not protect a trustee who applied for or accepted ownership of a policy knowing that the benefits were not payable to someone with an insurable interest, or knowing the policy was funded by someone without an insurable interest under an arrangement to transfer it onward. That is aimed at stranger originated life insurance, and it is a knowledge based exception rather than a strict one.

Sixteen years, no cases

This section was enacted in 2010. Our review found no decision citing it anywhere, in any Florida court, any Florida federal court, or the Eleventh Circuit, at any precedential status.

For a provision that removes fiduciary duties over what is often a family’s largest single asset, that is a remarkable silence, and it means several practical questions have no answer.

We publish the nil result as our own review rather than as a certainty.

A policy in trust that nobody has looked at

Whether the trustee owed a duty to look depends on an opt-in most people never made.

Frequently Asked Questions

Does a Florida trustee have to monitor life insurance held in a trust?

It depends on whether section 736.0902 has been switched on. If it has, the trustee has no duty to decide whether the policy remains a proper investment, to investigate the insurer's financial strength, to decide whether to exercise policy options, to diversify, or to inquire into the health or finances of the insured.

Is that safe harbour automatic?

Only one part of it. The duty to determine whether the policy complied with the insurable interest statute is switched off automatically for a policy on a qualified person. The other five duties are switched off only if the trust instrument invokes this section by reference, or the trustee gives the notice the statute describes.

Who is a qualified person?

A person who is insured or a proposed insured, or that person's spouse, who provided the trustee with the funds used to acquire the policy or pay the premiums on a policy insuring that person, their spouse, or both.

Can a beneficiary object?

Yes, and the objection works. If a person notified delivers a written objection to the trustee within 30 days of receiving the notice, the five substantive duties do not stop applying until the objection is withdrawn.

Does this let a trustee sell me a policy and then ignore it?

No. The section does not apply at all to a policy purchased from an affiliate of the trustee, or one on which the trustee or an affiliate receives a commission, unless the duties were delegated to someone else under section 518.112.

Can the trustee charge for this?

No. A trustee who performs services related to a policy covered by subsection (1) may not be compensated for performing the service the subsection covers.

Has any Florida court interpreted this section?

No. Our review found no citing decision anywhere, in the sixteen years since it was enacted.

Common Situations

You are trustee of a life insurance trust. Check whether the instrument invokes this section. If not, you still owe the five duties.

You received a notice about a policy. Thirty days from receipt, in writing, and the duties stay on.

The trustee sold the policy to the trust. The section does not apply where the trustee or an affiliate took a commission.

A policy lapsed and nobody noticed. Whether that is a breach depends on whether the safe harbour was ever switched on.

Sources of Law


Updated on August 16, 2026. Reviewed by Kevin D. Klagge, Esq., Fla. Bar No. 99502. Attorney Kevin Klagge represents families, businesses, and international clients in estate and tax planning, business structuring, and international law, with a focus on Florida legal tools. He litigates estate and business issues in court. General information about Florida law and published court decisions, not legal advice, and no attorney-client relationship is created. Reading this page does not make us your lawyers. Please do not send confidential details until we have connected.

Talk through a life insurance trust

Bring the trust and any notice you were sent. The opt-in is the whole question.