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FACC Louisiana Comment Letter 6/10/24

FACC commends the Louisiana Department of Insurance for moving forward in adopting updates to the National Association of Insurance Commissioners (NAIC) Model Regulation #275. The updated regulation incorporates best interest obligations in a manner that is attuned to the unique characteristics of the insurance industry. In particular, we support efforts

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Hispanic Leadership Fund Files Amicus Brief 6/3/24

The Hispanic Leadership Fund (“HLF”) has a strong interest in this case. DOL’s latest rule redefining who is an investment advice fiduciary (“2024 Fiduciary Rule”) is effectively the same as the very harmful 2016 Fiduciary Rule that was invalidated in a 2018 decision by the United States Court of Appeals

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U.S. Chamber of Commerce Files Amicus Brief 5/31/24

The Chamber of Commerce of the United States of America (“Chamber”) is the world’s largest business federation, representing approximately 300,000 direct members and indirectly representing the interests of more than three million businesses and professional organizations of every size, in every industry sector, and from every region of the country.

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FACC Oregon Comment Letter 5-28-2024

While FACC is pleased to see the Division move forward with creating permanent regulations to support SB 536 – designed to establish disclosure and care obligations for annuity sales – FACC stands with other major insurance trade associations in requesting the Oregon Division adhere to the NAIC model regulation and

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Complaint: FACC et al. vs DOL 05/02/2024

FACC is disappointed that the DOL has chosen to go down this same tired path with yet another proposal that blatantly violates the 2018 ruling by the Fifth Circuit and arrogantly ignores limitations of its authority under ERISA. The DOL’s new rules are yet another assault on the financial services

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Why the New DOL Fiduciary Rule Is Scarier Than Ever

DOL keeps resorting to the same script, which is to turn all agents and brokers into fiduciaries because apparently there is a lack of regulation around an industry that is otherwise awash in regulatory requirements. This is not intended to be cynical but reflects exasperation with the DOL’s 15-year fixation on extending its regulatory power through fiduciary duty.

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FACC Oregon Comment Letter 3-14-24

While in general FACC applauds the Division’s present efforts to adopt permanent rules implementing SB 536, and we appreciate the Division is proposing for the most part to adopt disclosure forms specified in the NAIC model regulation, we must take exception to the Division’s latest proposal to deviate from NAIC model forms by inclusion of non-conforming and confusing questions concerning duty of care. For reasons explained herein, we oppose such deviations from NAIC model forms and respectfully ask the Division to reconsider and remove those questions from the proposed forms.

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