Dear Director Froment:
We appreciate you have reached out and requested feedback on the following question outlined in Ms. Matthews May 22, 2019 email:
If the model would require “best interest” as the appropriate standard of conduct, how should “best interest” be defined in order to provide an objective standard for compliance and regulatory oversight?
As you know from our previously submitted comments, we oppose applying a security industry “best interest” standard to fixed annuities.