I. INTRODUCTION AND OVERVIEW -

Gary Gensler’s tenure-to-date as Chairman of the Securities and Exchange Commission (“SEC”) is striking for its exceptionally active rulemaking agenda. Two rulemakings of tremendous import to issuers and distributors of insurance products – tailored shareholder reports for mutual funds and exchange traded funds (“ETFs”)2 and a registration form tailored for registered index-linked annuities (“RILA’s”)3 – include amendments to advertising rules under the Securities Act of 1933 (“Securities Act”) and the Investment Company Act of 1940 (“1940 Act”).