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Tracey’s Test Post

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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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FACC v. DOL Amended Briefing Schedule

Government requests delay in briefing and argument schedule for FACC v. DOL. ELECTRONIC ORDER granting the [44] Joint Motion to Amend Case Schedule and modifying the current scheduling order [16] to set the following deadlines: November 7, 2022: Plaintiffs’ combined reply in support of their summary judgment motion and opposition

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FACC v. DOL Brief July 15, 2022

FACC v. DOL Brief July 15, 2022 This lawsuit presents the question of whether the DOL will be permitted to make an end run around a judgment rendered by the United States Court of Appeals for the Fifth Circuit. Through a strained reinterpretation of a long-standing regulation, the DOL has

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Complaint: FACC et al. v. DOL 02-02-2022

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION FEDERATION OF AMERICANS FOR CONSUMER CHOICE, INC.; JOHN LOWN d/b/a LOWN RETIREMENT PLANNING; DAVID MESSING; MILES FINANCIAL SERVICES, INC.; JON BELLMAN d/b/a BELLMAN FINANCIAL; GOLDEN AGE INSURANCE GROUP, LLC; PROVISION BROKERAGE, LLC; and V. ERIC COUCH,

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FACC Proceed Cautiously and Prudently

Dear Working Group Members:

The Fixed Annuity Consumer Choice Campaign (FACC Campaign)* was originally organized to address issues impacting fixed annuities in connection with Department Labor (DOL) fiduciary rule. While we were very pleased to see the Fifth Circuit strike down the DOL fiduciary rule, we are deeply concerned that state and federal regulators are now rushing to fill what they may perceive as a vacuum, thereby perpetuating inherent flaws and false justifications of the DOL fiduciary rule that led to its demise.

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FACC Best Interest Concerns: Cash and Non-Cash Compensation

Dear Working Group Members:
The Fixed Annuity Consumer Choice Campaign (FACC)* was organized to address certain issues impacting fixed annuities in connection with Department Labor (DOL) fiduciary rule. While generally FACC focuses its attention on DOL rule deliberations, we have reviewed the NAIC proposal to incorporate concepts of “best interest” into the NAIC’s model suitability regulation, and wish to comment on one particular point that may not otherwise be addressed by trade associations representing the industry.

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