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

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.

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.

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.

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

FACC is working hard to ensure that the NAIC Model for Best Interest is adopted as drafted by the NAIC so that it is workable for all agents and advisor in ALL states.   

FACC Proposes CRS Concept to NAIC Suitability Working Group Download to read the entire document.