Library

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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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.

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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.

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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.

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FACC Parking Lot List of Outstanding Issues

We want to share the attached list of “parking lot” issues which we prepared for purposes of identifying some of the larger issues that remain open for discussion in connection with the model suitability regulation.

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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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