For reasons explained herein, FACC must strongly oppose the proposal to amend Nevada’s suitability regulation as presently drafted. While we are pleased Nevada is seeking to update its regulations, FACC is extremely troubled by the extensive deviations from the NAIC model regulation found in this proposal, which will have adverse consequences for industry and the public, both foreseeable obstacles and unintended consequences. We urge the Department to withdraw this proposal and instead adopt the NAIC model regulation updates.