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South Dakota Comment Regarding Conflict of Interest

FACC opposes the proposed regulation which we believe is unnecessary, redundant, and potentially confusing.  While many states – 28 to date – have adopted the NAIC model regulation through rulemaking or legislation, none has seen the need to adopt a regulation similar to the one proposed here.  The reason is

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FACC v. DOL Amended Briefing Schedule

Government requests delay in briefing and argument schedule for FACC v. DOL. ELECTRONIC ORDER granting the [44] Joint Motion to Amend Case Schedule and modifying the current scheduling order [16] to set the following deadlines: November 7, 2022: Plaintiffs’ combined reply in support of their summary judgment motion and opposition

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FACC Comment to Tennessee Department of Insurance

FACC supports the proposal to amend Tennessee’s suitability regulation as currently draftedand publicly proposed.  FACC would strongly oppose any consideration of changes to the language that would deviate from the language contained in the NAIC Model #275.

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FACC v. DOL Brief July 15, 2022

FACC v. DOL Brief July 15, 2022 This lawsuit presents the question of whether the DOL will be permitted to make an end run around a judgment rendered by the United States Court of Appeals for the Fifth Circuit. Through a strained reinterpretation of a long-standing regulation, the DOL has

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FACC Comments on West Virginia Best Interest Proposal

FACC, the Federation of Americans for Consumer Choice, fully supports the efforts of West Virginia to adopt the updated NAIC Model regulation #275. We appreciate that West Virginia has proposed adopting the model regulation in full to enhance consumer protection and promote uniformity.

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FACC Comments on Utah Best Interest Proposal

Thank you for the opportunity to comment on proposed changes to R590-230, Suitability in Annuity Transactions. FACC applauds the Department’s efforts to adopt the updated version of the NAIC Model Regulation to enhance consumer protection and promote uniformity.

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FACC Comment Letter (FAQ)

FACC comments on next steps relative to the published FAQs and proposed FAQs for Training & Safe Harbor.  FACC actively supported the NAIC Working Group’s efforts to develop the existing FAQs and is grateful for the opportunity to have worked with other trade groups and regulators last year in completing

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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.

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FACC Lawsuit Talking Points

Please open the link below to read a letter prepared by FACC regarding our DOL lawsuit. We hope the letter provides industry colleagues with some insights about our legal action which we see as a critical component of industry efforts addressing DOL developments. The letter – among other things –

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