Papa Has a Brand New Bag
All in the Family – Introducing Family Owned Life Insurance™ (aka FOLI™)
TAKE A CHANCE ON ME! PART II - Embracing the Magic of Private Placement Life Insurance and Private Placement Variable Annuities
RETURN TO FOREVER - What Game Shall We Play Today?
NOWOTNY KNOWS SQUAT! Part IV Using Post-Retirement Medical Plans to Raise AUM and Sell Life Insurance
NOWOTNY ON DEATH AND TAXES EPISODE 35 USING POST-RETIREMENT MEDICAL PLANS TO RAISE AUM
NOWOTNY KNOWS SQUAT! Part 3 Using Malta Pension Plans to Raise AUM and Sell More Life Insurance
NOWOTNY KNOWS SQUAT! Part 2 Using PPLI and PPVA Annuities to Raise Assets Under Management and Sell More Life Insurance
INTRODUCING MALTA SPLIT DOLLAR
WHERE EAGLES DARE-INTRODUCING MALTA SPLIT DOLLAR
Private Placement Life Insurance Discussion Podcast
ISLA DEL ENCANTO - INTRODUCING BORICUA SPLIT DOLLAR
Isla del Encanto-Introducing Boricua Split Dollar
Everything You Need to Know About Beneficiary Designations
THE WONDER YEARS WEBINAR
HEAVEN CAN WAIT
What are the most important elements of estate and tax planning for US expatriates? Are you planning to move out of the United States? Are you a US taxpayer who lives and works outside of the country? What are some of the...more
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
On July 12, the SEC adopted, on a 3–2 party line vote, so-called money market fund reforms. The reforms substitute a required redemption (liquidity) fee for proposed “swing pricing” for certain institutional money market...more
Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more
The Uniform Gifts to Minors Act (UGMA) and the Uniform Transfers to Minors Act (UTMA) are sometimes called the “granddaddies” of college savings accounts. Both allow parents to establish custodial accounts for a minor child,...more
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
Mutual fund boards of directors need not meet in person to approve investment advisory contracts, Rule 12b-1 plans, or independent public accountants through December 31. ...more
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
Insurance and Investment Firms Breathe Easier - On December 4, 2019, the Financial Stability Oversight Council adopted final interpretive guidance on addressing systemic threats to the financial system that prioritizes the...more
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
Insurance companies filing amendments to registration statements for their variable product registration statements, as well as mutual funds, frequently rely on Rule 485(a). Under the rule, post-effective amendments filed by...more
In Release No. 33-10618 (Mar. 20, 2019), the SEC adopted amendments (the “Amendments”) that consolidate, conform, and otherwise refine numerous requirements applicable to filings with the agency. ...more
New Rules, Proposed Rules, Guidance and Alerts – NEW RULES – SEC Adopts New Rules Permitting Covered Investment Fund Research Reports – On November 30, 2018, the SEC adopted Rule 139b under the Securities Act of...more
The SEC staff now says that mutual fund directors can rely on chief compliance officer certifications in determining compliance with board procedures required by SEC exemptive Rules 10f-3, 17a-7, and 17e-1 under the...more
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
Executive Summary - In a significant step toward improving variable insurance product (“VIP”) disclosure, the U.S. Securities and Exchange Commission (“SEC”), on October 30, 2018, proposed a new rule (the “Summary Prospectus...more
On October 30, the SEC voted to propose modernized disclosures for variable annuities and variable life insurance policies (“variable insurance products” or “contracts”), including the use of an optional summary prospectus....more
New York Pushes Mutual Fund Active Share Disclosure - New York’s Attorney General issued a report on its recent investigation of fees charged by actively managed equity mutual funds and a metric known as “Active Share.”...more
New York’s Attorney General issued a report on its recent investigation of fees charged by actively managed equity mutual funds and a metric known as "Active Share." Denoted as a "percentage" from 0 to 100 percent, Active...more
On February 21, the SEC approved a six-month extension for mutual funds to comply with the classification (bucketing) requirements and related elements of its new liquidity rule....more
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
On December 7, the Investor Advisory Committee of the Securities and Exchange Commission (SEC) adopted a recommendation that the SEC seriously explore the development of a summary disclosure document for mutual fund companies...more
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
Regulators Demand Third-Party Risk Management - While third-party risk management has been a required component of an effective enterprise risk management program for many years, the topic is receiving elevated attention...more
A recent SEC no-action letter gives broker-dealers more time to perform suitability and other reviews when opening certain customer accounts. The firms requesting the letter were affiliated with three different insurance...more