Library

FACC Redline Sept Working Group Model Draft

Dear Ms. Matthews:
Jolie, as indicated in our submission earlier this week, we have continued to work on the redline and are now
submitting an updated version with further suggested edits. We ask that you incorporate these additional
edits into your summary chart.

Read More »

FACC Abbreviated Redline Transmittal Letter

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.

Read More »

FACC Abbreviated Redline

Draft: 9/17/19 FACC Redline 9/30/2019 NOTE: This mark –up is not meant to be definitive. Rather, it is meant to be illustrative of some, but not all, of our points raised in our comment letter. It is subject to continuing analysis and development. See download for full body of document.

Read More »

FACC Parking Lot List of Outstanding Issues

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.

Read More »

FACC to NAIC – Proposed Best Interest Rule Must ONLY Compare Insurance Agents to Other Insurance Agents! Preview Text: Read our comment to the NAIC

As you know by our comments, we support the standard put forward by Iowa in Section 6 A (1) (d), or something similar, because it provides a benchmark for determining what is meant by so many other undefined and open-ended terms like “best interest”, “best suited”, “care”, “skill”, “diligence” etc.

Read More »

FACC Supplemental Comment Section 6A1D

Dear Members of the Annuity Suitability Working Group

We wish to follow up on an important issue considered in this week’s phone call concerning the Care Obligation and ask for reconsideration.

We hope not to strain the patience of the Working Group, but we are perplexed by the decision to remove section 6 A (1) (d).

Read More »

FACC Response to Best Interest with CRS

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.

Read More »

3 Misconceptions about Best Interest

As the National Association of Insurance Commissioners considers amending the model suitability regulation, and as the U.S. Securities and Exchange Commission considers adoption of a parallel best interest proposal, the FACC Campaign finds certain misconceptions have taken root that must be addressed to ensure the ongoing debate is conducted based on facts and sound reasoning rather than preconceived notions or inaccurate assumptions. Kim O’Brien helped kill the DOL fiduciary rule. Here’s what she thinks about the new sales standards projects.

Read More »

OPEN LETTER TO LIFE INSURANCE AND ANNUITY TRADE ORGANIZATIONS

January 2019  TO: Trade Organizations with Members in the Independent Distribution Channel  RE: NAIC Best Interest Regulation  We the undersigned are Independent Marketing Organizations (IMOs) and many of us belong to trade organizations or work with companies that belong to trade associations. In the past few months we have been

Read More »