Dear Working Group Members:
The Fixed Annuity Consumer Choice Campaign (FACC)* was organized to address certain issues impacting fixed annuities in connection with Department Labor (DOL) fiduciary rule. While generally FACC focuses its attention on DOL rule deliberations, we have reviewed the NAIC proposal to incorporate concepts of “best interest” into the NAIC’s model suitability regulation, and wish to comment on one particular point that may not otherwise be addressed by trade associations representing the industry.