Skip to content


FACC Comment Letter (FAQ)

May 11, 2022 The Honorable Doug Ommen, ChairmanNAIC Annuity Suitability Working Group 1100 Walnut Street, Suite 1500Kansas City, MO 64106 Submitted via email to Jolie Matthews: RE:   Suitability in Annuity Transactions Model Regulation (#275) – Frequently Asked Questions (FAQs) Dear Commissioner Ommen: Thank you for the opportunity to comment on next steps relative to the

Read More »

FACC Letter Regarding May Lawsuit (May 2022)

Dear Friends, We wish to keep friends and colleagues advised of developments in our case as we had with our letter back in February – in which we explained the timing and rationale for our action against the U.S. Department of Labor – challenging its reinterpretation of the five-part test and withdrawal of the Deseret Letter all of which improperly expands the reach of ERISA and fiduciary requirements.

Read More »