Description: This paper provides guidance to employers who are contemplating the use of COLI as a means for funding employee benefits. Commentary will be provided on critical issues to consider when analyzing the benefits of COLI, including product characteristics, cost considerations, legal considerations, representations and warranties, investments, and accounting. “Best Practices” pricing guarantees, representations, warranties, and indemnities will be provided as examples and are generally indicative of the stronger positions taken to date on each issue. This paper does not provide guidance on group term life or other non-COLI products.