Those are excellent questions to consider. My aim was to view Insurance Services more as a whole than tiny parts.
I do see that you're correct that the appropriate categorization could depend on the nuances of the particular plan, insurance product/service, and whether it was direct advice to the plan or contract services.
For example, fees for true investment advice on annuity/insurance products as investment vehicles may potentially align better with investment advisory services than general insurance brokerage fees.
However, my understanding from closely reviewing the 2023 Instructions is that more common insurance services like premiums, policy placement, broker commissions, etc. are intended to be kept separate from investment management expenses on Schedule H.
But I agree the Instructions could provide clearer guidance across different insurance product and plan types. Considering the specific details you raised, rather than a one-size-fits-all approach, seems prudent.
Appreciate you outlining those nuanced factors to evaluate. If you have experience or insight into how the agencies view categorizing insurance services in certain scenarios, I'm certainly open to that feedback based on your expertise.