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Senators Grassley & Ernst Letter to DOL

Dear Secretary Scalia and Assistant Director Wilson:

We write today regarding the “Improving Investment Advice for Workers and Retirees” proposal recently issued by the Department of Labor.

We appreciate the Department’s intention to preserve diverse investment advice arrangements as compared to the 2016 Fiduciary Rule proposed by the prior Administration, as well as the Department’s goal of harmonizing industry regulation in order to protect consumers. However, we have heard concerns from Iowans regarding the impact that this proposed rule would have on insurance agents and their clients.

Kim O'Brien September 8, 2020 No Comments

FACC DOL Testimony

The Federation of Americans for Consumer Choice, FACC, appreciates the opportunity to testify today. Let me say at the outset that we are encouraged to see many other industry trade associations speak to the very real concerns of independent agents and independent insurance distribution.

Kim O'Brien September 3, 2020 No Comments

Press Release: DOL Rule is Flawed

The Federation of Americans for Consumer Choice (FACC), voicing deep concerns with the Department of Labor’s “Improving Investment Advice for Workers & Retirees” proposal, is urging DOL to reconsider its proposal. FACC submitted written comments to DOL outlining how the proposal will significantly disrupt the fixed insurance marketplace, turn traditional insurance agents into fiduciaries, and create unworkable hurdles for independent distribution.

Kim O'Brien August 12, 2020 No Comments

Press Release: FACC URGES DOL TO WITHDRAW OR REWORK INVESTMENT ADVICE RULE

Kim O'Brien August 12, 2020 No Comments

Federation of Americans for Consumer Choice DOL Comment Letter

RE: Improving Investment Advice for Workers & Retirees Proposal
To Whom it May Concern:
The Federation of Americans for Consumer Choice (FACC) wishes to express its deep concerns regarding the above proposal issued by the Employee Benefits Security Administration of the Department of Labor (herein the “Department” or “DOL”).

Kim O'Brien August 5, 2020 No Comments

NAIC Suitability & Best Interest Key Duties & Obligations

The new model regulation requires agents act in the “best interest” of clients without placing their own or the insurer’s financial interests ahead of client interests. An agent acts in the best interest of the client if the agent satisfies specific obligations regarding care, disclosure, conflict of interest, and documentation.

Kim O'Brien February 13, 2020 No Comments

FACC Comment Letter: Appendix A

Dear Members of the Annuity Suitability Working Group:

We wish to comment briefly on the proposed Producer Relationship Disclosure form contained in Appendix A. We appreciate the Working Group may not be looking for additional comment but we are reacting to submissions by other interested parties which go to the premise of the form itself.

Kim O'Brien December 16, 2019 No Comments

FACC Supports Independent Insurance Producers

The Fixed Annuity Consumer Choice Campaign has been working hard to improve the NAIC best interest proposal for the benefit of independent agents. We have advocated changes to make the rule more objective in its requirements and more practical from an implementation and compliance standpoint.

Kim O'Brien December 11, 2019 No Comments

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.

Kim O'Brien October 5, 2019 No Comments

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.

Kim O'Brien September 30, 2019 No Comments