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A Sea Change in RILA Regulation: Navigating the New Waters

On July 1, 2024, the Securities and Exchange Commission adopted a new registration framework for registered index-linked annuity (RILA) contracts. RILA contracts allow investors to allocate purchase payments to one or more...more

New SEC RILA Rules: Implementation Issues and Practical Considerations

On July 1, 2024, the Securities and Exchange Commission (SEC) announced new rules for registered index-linked annuities (RILAs) and registered market-value adjustment annuities (MVAs). The new rules will significantly impact...more

Expect Focus - Volume I, January 2023

More than 25 years have elapsed since the SEC adopted Exchange Act Rule 17a-4(f) governing electronic recordkeeping by broker-dealers. In an effort to update the rule to reflect “technology neutral” concepts, the SEC adopted...more

Executive Compensation Disclosure – Partial Relief for Insurance Products

For many years, insurance company issuers of non-variable products that are registered with the SEC on Forms S-1 or S-3 have been required to disclose compensation information about highly-compensated executive officers of...more

Expect Focus - Volume III - September 2017

EXPECTFOCUS® is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more

Back to the Future: 2017 [Expect Focus Life Insurance – December 2016]

- Should Your Company Purchase Bitcoin to Pay a Cyber Ransom? - NAIC Draws Line in CFPB Sandbox - NAIC’s Big Data Task Force Sets Charges for 2017 - Broker-Dealers Can Hold Customers’ Initial Checks...more

FINRA Fines Firms For Not Supervising L-Share Annuity Sales

For two years FINRA has made sales and marketing of L-Share variable annuities (VAs) a regulatory and examination priority. Not surprisingly, FINRA in November announced settled actions against eight broker-dealers, alleging...more

“Promptly Transmit” Redefined for Some Customer Checks

The SEC and FINRA recently extended relief originally granted to accommodate suitability reviews of deferred variable annuities, so that the relief is now also available for mutual funds, Section 529 plans, and other...more

Variable Annuities Still In The Crosshairs

For the first time in several years, variable annuities are not listed as a priority in FINRA’s annual letter of regulatory and examination priorities. The omission from the January 2, 2014, letter may be partly due to the...more

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