“FACC welcomes efforts of the Department of Banking and Insurance to adopt the updated National Association of Insurance Commissioners (NAIC) Model Regulation #275 incorporating best interest obligations into existing suitability regulations. Assuming it is the intent of the Department to adopt the NAIC model regulation updates in their entirety, FACC

“FACC overall is pleased with and supports the proposal published on the Department website as Revised Proposed Regulation R109-23. FACC commends the Division for its continuing efforts and general adherence to the updated 2020 NAIC Suitability in Annuity Transactions Model #275. FACC believes adoption of the updated NAIC model regulation

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

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

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.

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

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.

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.