News & Analysis as of

Investment Management Annuities

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (33): The DOL’s Final PTE 84-24

On April 25, 2024, the Department of Labor published its final regulation defining fiduciary status for investment advice and the related exemptions—PTE 2020-02 and 84-24. The exemptions provide relief from prohibited...more

Mayer Brown

United States: The Long Read - Lifetime Income Products in CITs on the Rise

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As recently noted by the US Department of Labor (“DOL”), since the passage of the Employee Retirement Income Security Act of 1974 (“ERISA”), “the retirement plan landscape has changed significantly, with a shift from defined...more

Carlton Fields

Expect Focus - Volume III, September 2023

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Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more

Adler Pollock & Sheehan P.C.

Is a Split Annuity Strategy Right for You?

The average length of retirement is 18 years, according to the U.S. Census Bureau. And with today’s medical technology, it could last significantly longer. Thus, a major challenge is balancing the need to maintain your...more

Gerald Nowotny - Law Office of Gerald R....

Family Affair – Introducing Family Office Life Annuity™ (aka FOLA™)

Most of you know by now that I grew up in the Panama Canal Zone which no longer exists as of 1999. In that respect, the transition left me as a man without a country. My father (of blessed memory) when referring to kids...more

Gerald Nowotny - Law Office of Gerald R....

Somewhere Over the Rainbow

Nowotny on Death and Taxes, episode 7, Somewhere Over the Rainbow, is about the use of private placement variable deferred annuities (PPVA) and trusts. ...more

Faegre Drinker Biddle & Reath LLP

SECURE Act and Guaranteed Income (Part 2)

The introduction to my last post, SECURE Act Part 1, explained: There are two parts of the SECURE Act that I believe will have the greatest impact on my clients: plan sponsors and plan service providers. The first includes...more

Troutman Pepper

Investment Management Roundtable Discussion – Personal Estate Planning

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Gregory J. Nowak, a partner and practice leader for hedge funds in Pepper Hamilton’s Private Fund Services Practice Group, hosts a series of candid, interactive webinar discussions for West LegalEdcenter on what is going on...more

Carlton Fields

Buffer ETFs vs. Index-Linked Annuities

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Like most ETFs, the buffer ETFs are registered with the SEC on Form N-1A as “open-end” investment companies, and they issue and redeem their shares at net asset value (NAV) only as part of large blocks, known as “creation...more

Ballard Spahr LLP

Investment Management Update

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Here in is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry....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

Carlton Fields

SEC Regulation Best Interest: Charting a Course for Securities and Annuity Sales

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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

Burr & Forman

Is There Anything Left of the Fiduciary Rule?

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The issue over the Fiduciary Rule, and whether it will be implemented, revised, vacated, forgotten, etc. has been ongoing. In March 2018, the Fifth Circuit Court of Appeals ruled in favor of several business groups who...more

Carlton Fields

Expect Focus - Volume IV, December 2017

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EXPECTFOCUS is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more

Carlton Fields

Treasury Department Urges SEC to Act on Life Company Products

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The U.S. Department of the Treasury published an October 2017 report, "A Financial System That Creates Economic Opportunities — Asset Management and Insurance" in response to President Trump’s Executive Order 13772 on "Core...more

Carlton Fields

Did Santa Give the Insurance Industry a Lump of Coal or a Diamond in the Rough? The Proposed Suitability and Best Interest...

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As reported in our November 28 client alert, the National Association of Insurance Commissioners’ (NAIC) Annuity Suitability Working Group (Suitability WG) circulated the proposed Suitability and Best Interest Standard of...more

Carlton Fields

The DOL Fiduciary Rule: Charting a Course, Avoiding Collisions & Potential Litigation Q&A #4 - Q&As on Annuity Sales Practices,...

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For the past several months, we have written about potential litigation issues under the “revised temporary” DOL Rule involving the offer and sale of annuities in the IRA market. This article continues that discussion. ...more

Carlton Fields

New York Department of Financial Services Rings in the New Year with New Suitability Requirements for Insurance Companies

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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

Carlton Fields

The DOL Fiduciary Rule: Charting A Course, Avoiding Collisions & Potential Litigation Q&A #4 - Q&As on Annuity Sales Practices,...

Carlton Fields on

For the past several months, we have written about potential litigation issues under the “revised temporary” DOL Rule involving the offer and sale of annuities in the IRA market. This article continues that discussion. Recall...more

Carlton Fields

Expect Focus - Volume III - September 2017

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EXPECTFOCUS® is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more

Carlton Fields

SEC Scrutinizes Multi-Manager Arrangements

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Many mutual funds implement their investment strategies through "multi-manager" (also called "manager of manager") arrangements, particularly funds used to support variable life insurance and annuity products. Among other...more

Vedder Price

Investment Services Regulatory Update - August 2017

Vedder Price on

On August 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert providing a summary of the staff’s observations from sweep exams of broker-dealers, investment advisers and funds...more

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