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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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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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