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FACC Parking Lot List of Outstanding Issues

Submitted electronically to

TO: Jolie Matthews
Senior Health and Life Policy Counsel

National Association of Insurance Commissioners (NAIC) 444 North Capitol Street, NW
Hall of the States, Suite 700
Washington, DC 20001-1509

Contact: Kim O’Brien, FACC Spokesperson & Americans for Annuity Protection, Vice Chair 414-332-9312

Re: Supplemental List of Parking Lot Issues

We want to share the attached list of “parking lot” issues which we prepared for purposes of identifying some of the larger issues that remain open for discussion in connection with the model suitability regulation.

FACC commends Director Froment for coming up with this idea of a “parking lot” in order to identify important issues that could be put on the side and taken up at a later point in the process. However, we do not believe any such list of issues was ever formally assembled or distributed so we thought it might be helpful to prepare such a list and share it with the NAIC and other interested parties.

We recognize the working group may believe some of these parking lot issues were addressed to some extent in prior sessions but our view is these larger issues have not yet been fully considered and resolved and have kept them on the list in light of their importance and need for further review.

We wish to emphasize the list is not exhaustive and also that working group members or other interested parties may believe there are additional issues – beyond these – in need of further review and attention. We already shared a version of this list and discussed it with certain members of the working group but thought it might be helpful at this point in the process to share the list more broadly.

FACC would welcome the posting of this list on your website so it may be shared with the Suitability Working Group, interested parties and other stakeholders.

Thank you for your time and efforts, as always.

Kim O’Brien

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