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Unpacking the SEC’s Regulation Best Interest Package

On June 5, 2019, the SEC adopted a four-part regulatory package that includes: new Regulation Best Interest (Reg. BI), the related “Relationship Summary” disclosure form (Form CRS), and two interpretations of the Advisers...more

Suitability Working Group Stirs Ingredients for Suitability Model Potion

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 The Duty Of Care Race, The NAIC Is In The Chase With New Proposed Revisions To Its Annuity Suitability Model

On July 24, in preparation for its August 4 meeting at the NAIC 2018 Summer National Meeting, the Annuity Suitability (A) Working Group (the “Suitability WG”) peddled fast and released a working draft of proposed revisions...more

State Suitability, Fiduciary Duty and Disclosure Initiatives Roundup

States are stampeding to impose additional duties on those who provide financial advice or make recommendations to consumers. Some of these initiatives result from the states’ belief that action is required to wrangle...more

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