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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”).

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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.

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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.

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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).

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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.

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