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Illinois Comment Regarding NAIC Suitability Proposal

FACC comments on one apparent deviation in the proposed amendments from the NAIC model regulation.  We note a portion of Section 1.B of the model regulation was not included in the Illinois proposal in its entirety as represented by the underlined language: Nothing herein shall be construed to create or

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South Dakota Comment Regarding Conflict of Interest

FACC opposes the proposed regulation which we believe is unnecessary, redundant, and potentially confusing.  While many states – 28 to date – have adopted the NAIC model regulation through rulemaking or legislation, none has seen the need to adopt a regulation similar to the one proposed here.  The reason is

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FACC Comment to Tennessee Department of Insurance

FACC supports the proposal to amend Tennessee’s suitability regulation as currently draftedand publicly proposed.  FACC would strongly oppose any consideration of changes to the language that would deviate from the language contained in the NAIC Model #275.

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FACC Comments on West Virginia Best Interest Proposal

FACC, the Federation of Americans for Consumer Choice, fully supports the efforts of West Virginia to adopt the updated NAIC Model regulation #275. We appreciate that West Virginia has proposed adopting the model regulation in full to enhance consumer protection and promote uniformity.

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FACC Comments on Utah Best Interest Proposal

Thank you for the opportunity to comment on proposed changes to R590-230, Suitability in Annuity Transactions. FACC applauds the Department’s efforts to adopt the updated version of the NAIC Model Regulation to enhance consumer protection and promote uniformity.

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FACC Comment Letter (FAQ)

FACC comments on next steps relative to the published FAQs and proposed FAQs for Training & Safe Harbor.  FACC actively supported the NAIC Working Group’s efforts to develop the existing FAQs and is grateful for the opportunity to have worked with other trade groups and regulators last year in completing

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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.

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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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