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South Dakota Comment Regarding Conflict of Interest

FACC opposes the proposed regulation which we believe is unnecessary, redundant, and potentially confusing.  While many states – 28 to date – have adopted the NAIC model regulation through rulemaking or legislation, none has seen the need to adopt a regulation similar to the one proposed here.  The reason is simple.  This regulation is not needed because it attempts to clarify aspects of the regulation that are already clear on their face.  In doing so, this proposed regulation only serves to invite confusion and misunderstanding. 

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