On December 18, 2019, the Securities and Exchange Commission (SEC) issued a proposed rule – “Amending the ‘Accredited Investor’ Definition” (the Proposed Rule) – that would expand access to private funds for certain...more
12/23/2019
/ Accredited Investors ,
Capital Raising ,
Comment Period ,
Family Offices ,
Institutional Investors ,
Private Funds ,
Private Placements ,
Registered Investment Advisors ,
Registered Investment Companies (RICs) ,
Regulation D ,
Rule 506 Offerings ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC)
The Securities and Exchange Commission (SEC) is subject to the current federal government shutdown due to lack of funding, and generally it will follow its “Operations Plan Under a Lapse in Appropriations and Government...more
The US Securities and Exchange Commission (SEC or Commission) recently proposed a new disclosure framework for SEC-registered variable annuity contracts and variable life insurance policies (together, variable contracts) that...more
The Securities and Exchange Commission (SEC) on June 5, 2018, adopted Rule 30e-3 under the Investment Company Act (the Rule), which permits “notice and access” delivery of investment company shareholder reports via website...more
On December 13, the National Association of Insurance Commissioners (NAIC) Executive (EX) Committee and Plenary adopted revisions to Actuarial Guideline 49 (AG 49) with an effective date of March 1, 2017. The revisions apply...more
On October 13, 2016, the SEC approved new Rule 22e-4 under the Investment Company Act of 1940, as amended (the 1940 Act), which will require certain open-end investment companies other than money market funds, to adopt and...more
On October 20, the NAIC Life Actuarial (A) Task Force (LATF) of the Life Insurance and Annuities (A) Committee met and approved proposed revisions to Actuarial Guideline 49 (AG 49) for exposure and comment. If adopted, the...more
On July 27, 2016, the Life Insurance and Annuities (A) Committee adopted revisions to Actuarial Guideline 49 (AG 49) to address situations where indexed universal life (IUL) insurance policies make available multiple index...more
The National Association of Insurance Commissioners (NAIC) held its 2016 Spring National Meeting from April 1 through April 6 in New Orleans, Louisiana. As host, Louisiana provided beautiful weather and bountiful great food....more
5/25/2016
/ Big Data ,
Casualty Insurance ,
Cybersecurity ,
Department of Labor (DOL) ,
Fiduciary Duty ,
Flood Insurance ,
Gramm-Leach-Blilely Act ,
IAIS ,
Individual Retirement Account (IRA) ,
Insurance Industry ,
Life Insurance ,
NAIC ,
ORSA ,
Pricing ,
Principle-Based Reserves ,
Property Insurance ,
Reinsurance ,
Terrorism Insurance
On May 5, 2016, the IRS issued Notice 2016-32, 2016-21 I.R.B. 1, which affords relief with respect to the application of the diversification requirements of IRC § 817(h) to variable life insurance and annuity contracts...more
On February 24, the IUL Illustration (A) Subgroup of the Life Actuarial (A) Task Force approved proposed revisions to Actuarial Guideline 49 (A.G. 49) for exposure and comment. Among other things, A.G. 49, which was adopted...more
On November 3, the National Association of Insurance Commissioners (NAIC) IUL Illustration (A) Subgroup circulated for comment proposed revisions (Proposed Revisions) to recently adopted Actuarial Guideline 49 governing...more
On June 4, after long deliberation and extensive consultation with issuers of indexed universal life (IUL) insurance policies and other interested parties by the Life Actuarial (A) Task Force (LATF), the NAIC’s Life Insurance...more
Late this summer, the Massachusetts Treasurer demanded mutual fund records on a nationwide basis as part of a multistate unclaimed property audit. Thirty-five (35) states are involved in the audit, but the Treasurer has...more
On August 26, the U.S. Court of Appeals for the First Circuit held in Vander Luitgaren v. Sun Life Ass. Co. of Canada, No. 13–2090, 2014 WL 4197947 (1st Cir. Aug. 26, 2014), that an insurer, acting as a claims administrator,...more
On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission, and the Commodity Futures Trading...more
1/15/2014
/ Bank Holding Company Act ,
Banks ,
CFTC ,
Collateralized Debt Obligations ,
Dodd-Frank ,
Federal Reserve ,
OCC ,
Proprietary Trading ,
Securities and Exchange Commission (SEC) ,
Trust Preferred Securities ,
Volcker Rule
On December 12, 2013, the Federal Insurance Office (FIO) of the U.S. Department of the Treasury released its much anticipated study, How to Modernize and Improve the System of Insurance Regulation in the United States...more
On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Securities and Exchange Commission and the Commodity Futures...more
1/13/2014
/ Bank Holding Company Act ,
Banks ,
CFTC ,
Collateralized Debt Obligations ,
Compliance ,
Dodd-Frank ,
FDIC ,
Federal Reserve ,
OCC ,
Proprietary Trading ,
Trust Preferred Securities ,
Volcker Rule
In a substantial victory for the life insurance industry on the unclaimed property issue, a West Virginia Circuit Court has held that insurers have no duty to search the Social Security Administration’s Death Master File...more
In the first federal appellate decisions addressing cost of insurance (COI) charges in life insurance policies, the Seventh Circuit Court of Appeals handed two victories to insurers in opinions issued December 13, 2013. In...more
On December 10, 2013, five federal agencies, including the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission, and the...more