WHERE HAVE YOU GONE, CHIP HILTON?
Somewhere Over the Rainbow
Investment Management Roundtable Discussion – Personal Estate Planning
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
The Mitchell Williams Insurance Regulatory team of lawyers recently attended the National Association of Insurance Commissioners (NAIC) 2022 Summer National Meeting which was held in Portland, Oregon on August 9-13th. We have...more
Lifetime Income Disclosure Requirement. The Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”), enacted December 20, 2019, added a new annual disclosure requirement for benefit statements to...more
In the span of the last five months, the Securities and Exchange Commission (SEC) and its staff have issued two statements, a risk alert and an exam priorities roadmap, all of which address digital assets in full or in part....more
Earlier this year, we discussed the lifetime income disclosure requirement that was included in the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”). When the disclosure requirement becomes...more
The SECURE Act of 2019 made three statutory changes to ERISA regarding lifetime income benefit payments from defined contribution plans (e.g., 401(k), 403(b), profit sharing, and money purchase pension plans). This blog will...more
The NAIC Virtual Summer National Meeting marked that it is time to get back to school for a number of annuity and life disclosure and illustration initiatives. Both regulators and insurers will need to sharpen their pencils...more
On December 30, 2019, the Life Insurance and Annuities (A) Committee approved a revised Suitability in Annuity Transactions Model Regulation (Revised Suitability Model), ending a flurry of activity over the past year....more
Ohio Department of Insurance Director Jillian Froment, the new chair of the Annuity Suitability Working Group (Working Group), invited regulators and interested parties to build the required standard of care foundation for...more
The NAIC’s Annuity Disclosure Working Group and IUL Illustration Subgroup continue to chalk out changes to the Annuity Disclosure Model Regulation (Model) and Actuarial Guideline 49 (AG 49) to address index product...more
Broker-dealers selling annuity products in New York will soon need to comply with new best interest requirements imposed by New York’s amended Insurance Regulation 187. These requirements, which will take effect for annuities...more
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
I. Overview of the Summary Prospectus Proposal - In a long-awaited development, the Securities and Exchange Commission (SEC or Commission), on October 30, 2018, issued a proposal consisting of new rules and registration...more
As promised, the Fed on Wednesday announced “one of the most significant rollbacks of bank rules” since the White House changed hands in the form of a draft proposal that would loosen capital and liquidity requirements for...more
On October 22 and 23, the NAIC Annuity Suitability (A) Working Group (Suitability WG) held an interim meeting to review comments received on the Suitability in Annuity Transactions Model Regulation (Model 275) (Suitability...more
In June, we circulated our fifth article on the continuing saga regarding the standard of conduct for sales of securities and annuities — and the efforts of federal and state regulators to impose new conditions on the...more
On May 31 and June 1, several teams competed over proposed revisions to the Suitability in Annuity Transactions Model Regulation (#275) (Suitability Model) at the in-person meeting of the National Association of Insurance...more
Annuity Illustration Standard Changes: On March 2, the Annuity Disclosure (A) Working Group of the National Association of Insurance Commissioners agreed to recommend the adoption of a revision to the NAIC’s Annuity...more
New York’s Department of Financial Services decided to bid farewell to 2017 and ring-in the new year by proposing to amend Suitability in Annuity Transactions, 11 NYCR 224 (the Annuity Suitability Rule). On December 27, 2017,...more
In California, actions predicated on alleged senior notice requirement violations and financial elder abuse continue to challenge life insurers. For example, in June, a California federal district court denied the insurer’s...more
On September 19, the New York Department of Financial Services promulgated the final version of new Regulation 210 “Life Insurance and Annuity Non-Guaranteed Elements” (the “Rule”).The Rule takes effect on March 19, 2018....more