Dear Members of the Annuity Suitability Working Group:

The FACC Campaign appreciates the time and effort the Group has dedicated over the past 18 months and welcomes the opportunity to comment on the newest September Working Group Draft. While there are certain features of the proposal that are improved, we are generally disappointed with the latest proposal because it suffers from the same problems as prior drafts.

We want to share the attached list of “parking lot” issues which we prepared for purposes of identifying some of the larger issues that remain open for discussion in connection with the model suitability regulation.