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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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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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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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FACC Missouri Comment Letter 03-15-24

We appreciate the proposed amendment follows the changes to the NAIC Model Regulation.  We believe the work that the Department has done is important to ensure uniformity and consistency across many jurisdictions which makes implementation more cost effective for industry and ultimately benefits everyone including consumers.  We trust the final adopted regulation

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FACC Comment Letter 12-11-23 – Nevada Rule Proposal

For reasons explained herein, FACC must strongly oppose the proposal to amend Nevada’s suitability regulation as presently drafted. While we are pleased Nevada is seeking to update its regulations, FACC is extremely troubled by the extensive deviations from the NAIC model regulation found in this proposal, which will have adverse consequences for industry and the public, both foreseeable obstacles and unintended consequences. We urge the Department to withdraw this proposal and instead adopt the NAIC model regulation updates.

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Indiana Comment Letter

FACC has previously provided comments to the Department and commends its initiative in proposing regulations that align with the NAIC Model Regulation on Suitability in Annuity Transactions. We wish to express our continuing gratitude to you and others at the Department for moving forward with these regulations.

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FACC Final Comment to Utah

The NAIC model and many other states permit insurance companies and producers to utilize producer disclosures that are “substantially similar to NAIC Appendices A, B, and C.” Many insurers and producers are already using those disclosure forms in other states and it would help insurance companies and producers if Utah conformed to the NAIC model language. Specifically, we ask that the Rule be modified to say “the producer shall prominently disclose to the consumer on a form substantially similar to the 2020 NAIC Model #275 Suitability in Annuity Transactions Appendix A”. Parallel wording could be used for the other appendices as well. As you can appreciate, this is important to enable insurance companies and producers to utilize the same forms across all jurisdictions that have adopted the NAIC model.

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New Hampshire Comment Letter

The NAIC model and many other states permit insurance companies and producers to utilize producer disclosures that are “substantially similar to” NAIC Appendices A, B, and C. Many insurers and producers are already using those disclosure forms in other states and it would help insurance companies and producers if New Hampshire conformed to the NAIC model language.

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Washington Comment Letter

FACC would like to make one suggestion to the Department which is to promulgate another rule that would specify content of the required disclosures referenced in the updated statutes consistent with the NAIC Model Regulation as set forth in Appendices A, B, and C. HB 1120 provides that the Department shall post the Appendices on its website which FACC presumes will be the same forms as provided in the NAIC Model Regulation. FACC requests the Department consider adopting the NAIC appendices through a regulation that could lay out the sample forms or incorporate the NAIC forms by reference. Such promulgation, or incorporation of the NAIC forms by reference, would ensure that Washington is consistent with the NAIC model regulation in regard to disclosure requirements and provide certainty to regulated parties both now and into the future.

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FACC Comment to Kansas Proposed Best Interest Rule

FACC believes the NAIC Model Regulation provides strong consumer protection while at the same time preserving consumer choice through well-balanced thoughtful regulatory requirements consistent with different delivery systems in the marketplace. We have long held that it is important for states to adopt the model requirements uniformly without deviation so as to leverage the expertise of the NAIC and so that companies and agencies operating across state boundaries can comply efficiently and utilize uniform practices that most effectively serve consumer interests.

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