FACC believes the NAIC Model Regulation provides strong consumer protection while at the same time preserving consumer choice through well-balanced thoughtful regulatory requirements consistent with different delivery systems in the marketplace. We have long held that it is important for states to adopt the model requirements uniformly without deviation so as to leverage the expertise of the NAIC and so that companies and agencies operating across state boundaries can comply efficiently and utilize uniform practices that most effectively serve consumer interests.
Kansas Insurance Department
1300 SW Arrowhead Road
Topeka, Kansas 66604
Via email to: KID.publiccomment@ks.gov
Re: K.A.R. 40-1-53 – Suitability in Annuity Transactions
FACC, the Federation of Americans for Consumer Choice, appreciates the opportunity to comment on the proposed Policy and Procedure Regarding Suitability in Annuity Transactions replacing existing K.A.R. 40-2-14a with newly proposed K.A.R. 40-1-53.
FACC commends the Kansas Insurance Department for moving forward in adopting updates to the National Association of Insurance Commissioners (NAIC) Model Regulation #275. The updated regulation incorporates best interest obligations in a manner that is attuned to the unique characteristics of the insurance industry. In particular, we support efforts by the Department to adopt the updated NAIC model regulation because it promotes uniformity and consistency across the large majority of states that have now adopted the updated NAIC model regulation.
FACC and its members, consisting of independent distributors selling mostly fixed life insurance and annuity products, believe the NAIC Model Regulation provides strong consumer protection while at the same time preserving consumer choice through well-balanced thoughtful regulatory requirements consistent with different delivery systems in the marketplace. We have long held that it is important for states to adopt the model requirements uniformly without deviation so as to leverage the expertise of the NAIC and so that companies and agencies operating across state boundaries can comply efficiently and utilize uniform practices that most effectively serve consumer interests.
The Kansas Department is to be applauded for joining a growing list of states – at this point thirty-six other states with several more in queue – in adopting this modernized regulation which we are confident will positively benefit consumers of annuity products and thereby promote retirement security for all Kansans approaching or in their retirement years.
Again, thank you for the opportunity to comment.
Sincerely,
Kim O’Brien, CEO
