News & Analysis as of

Disclosure Requirements Life Insurance

Carlton Fields

Expect Focus - Volume II, May 2024

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Last Lap in SEC RILA Rulemaking Critical Unresolved Issues - Congress directed the SEC to adopt a new registration statement for registered indexed annuities (RILAs) by the end of June. Several months ago, the SEC...more

Mitchell, Williams, Selig, Gates & Woodyard,...

National Association of Insurance Commissioners (NAIC) 2022 Summer Meeting Summary

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

Carlton Fields

NAIC Illustration Work Stagnates in the Dog Days of Summer

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The NAIC groups working on illustration issues reported little activity at the 2021 NAIC Summer National Meeting. The Life Insurance Illustration Issues (A) Working Group’s (Life Illustration WG) charge has been to...more

Carlton Fields

Back to School for Annuity and Life Disclosures and Illustrations

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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

Carlton Fields

SEC Proposes Big Changes to Fund Disclosure

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The SEC has proposed “comprehensive modifications to the mutual fund … disclosure framework,” as highlighted below. More detailed analysis of the proposal is also available in our legal alert. See “SEC Proposes Changes to...more

Carlton Fields

Variable Product Disclosure Reform: Decision Points for Insurers

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Implementing all the reforms adopted by the SEC in connection with its variable insurance product summary prospectus rule (Rule 498A) is potentially a major undertaking, depending on the number and nature of an insurer’s...more

Eversheds Sutherland (US) LLP

SEC adopts groundbreaking disclosure improvements for variable insurance contracts 

On March 11, 2020, the Securities and Exchange Commission (“SEC” or “Commission”) adopted a new prospectus disclosure framework, including new rules, rule amendments and registration statement form amendments, for...more

Vedder Price

SEC Adopts New Variable Contract Summary Prospectus Rule

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New Streamlined Disclosure Approach for Variable Contracts - Yesterday, the Securities and Exchange Commission (SEC) adopted Rule 498A – the long-awaited variable contract summary prospectus rule. The new rule represents...more

Carlton Fields

NAIC Life Insurance and Annuities (A) Committee Ends 2019 With a Big Bang

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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

Carlton Fields

SEC Pressures Advisers on Undisclosed Conflicts

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We are actively looking for circumstances where an adviser is financially conflicted by incentives that could affect investment recommendations to clients. ... And I will tell you: the more we look, the more undisclosed or...more

Carlton Fields

New SEC Regulation Defines ‘Best Interest’ Flexibly

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Each Broker-Dealer Can Help Shape Concept Appropriately to Its Business - The SEC’s new Regulation Best Interest (Reg BI) requires broker-dealers to: - Disclose business practices in dealing with retail customers; and ...more

Carlton Fields

SEC Expands Manager-of-Managers Relief to Affiliated Sub-Advisers

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On May 29, 2019, the SEC granted an exemptive order to Carillon Series Trust and Carillon Tower Advisers Inc. (a Raymond James affiliate) to hire and replace affiliated and unaffiliated sub-advisers without shareholder...more

A&O Shearman

Asset managers, life insurance companies and pension funds: engage or explain

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On 1 August 2019, the Luxembourg legislator implemented the second shareholder right directive (SRD II) by amending the law of 24 May 2011 relating to the exercise of certain shareholder rights at general meetings of listed...more

Carlton Fields

DC Circuit: Willful Means Intentional Under the Advisers Act – Negligent Conduct Cannot Be Willful Conduct

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In Robare Group v. SEC, the court clarified the meaning of “willfully” under Section 207 of the Investment Advisers Act of 1940. A willful omission requires that a person “subjectively intended to omit material information.”...more

Carlton Fields

Unpacking the SEC’s Regulation Best Interest Package

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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

Carlton Fields

Changes to the Index Product Illustration Requirements Are No Child’s Play

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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

Womble Bond Dickinson

Insuretech and Beyond – An Evolving Litigation Landscape Association of Life Insurance Counsel Annual Meeting May 2019

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In recent years, the life insurance industry has greatly enhanced the speed and efficiency of its underwriting decisions. This change in the underwriting process is due in large part to the use of new technology in data...more

Carlton Fields

UCL and Financial Elder Abuse Claims Against Life Insurer Are Time-Barred

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Life insurers in California are all too familiar with claims based on alleged violations of senior notice statutes and financial elder abuse. ...more

Eversheds Sutherland (US) LLP

New York Circular Letter No. 1 (2019) takes aim at accelerated underwriting

On January 18, 2019, the New York Department of Financial Services (NYDFS) issued a circular letter to all insurers authorized to write life insurance in New York State setting out the Department’s views concerning the use of...more

Akin Gump Strauss Hauer & Feld LLP

DFS Issues Guidance to Life Insurers on Use of “External Data” in Underwriting Decisions

On January 18, 2019, New York’s Department of Financial Services (DFS) issued Circular Letter No. 1 (2019) to advise life insurers regarding the type of data that they may use when underwriting policies. The guidance was...more

Carlton Fields

SEC Proposes Summary Prospectus Option and Modernized Disclosure for Variable Insurance Products (UPDATED)

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On October 30, the SEC voted to propose modernized disclosures for variable annuities and variable life insurance policies. The proposal would permit...more

Carlton Fields

Executive Compensation Disclosure – Partial Relief for Insurance Products

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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

Vedder Price

The SEC’s Variable Contract Summary Prospectus and Disclosure Enhancement Proposals—Synopsis and Areas for Industry Comment

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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

Eversheds Sutherland (US) LLP

SEC proposes new variable contract disclosure regime

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

Orrick - Finance 20/20

SEC Proposed Disclosure Improvements for Variable Annuities and Variable Life Insurance Contracts

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On October 30, the Securities Exchange Commission (“SEC“) announced it voted to propose rule changes intended to improve disclosure for investors about variable annuities and variable life insurance contracts. Such...more

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