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
The PRA has released an important statement on its approach to funded reinsurance. Our view is that the statement endorses the conceptual principle that funded reinsurance (particularly to offshore counterparties) should best...more
On April 24, 2024, the New York State Department of Financial Services (NYDFS) published Proposed Rule Making for the 13th Amendment to Insurance Regulation 17, 20 and 20-A (Proposed Amendment), which purports to implement...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
We previously reported on regulators’ increased attention to the use of big data systems, including external consumer data and information sources, algorithms and predictive models. Recent announcements in Colorado, Louisiana...more
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
The National Association of Insurance Commissioners (NAIC) held its 2020 Summer National Meeting virtually from July 28 to August 14, 2020. The meeting was originally scheduled to be held in Minneapolis, Minnesota, but was...more
On August 14, at its all-virtual summer national meeting, the National Association of Insurance Commissioners (NAIC) adopted guidance governing illustrations for index-based life insurance. In a key development, New York...more
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
Arizona jumped out front of the pack with the introduction of Senate Bill No. 1557, titled "Annuity Transactions; Requirements," which would amend Arizona's suitability requirements for annuity transactions. Senate Bill No....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
Like a game of whack-a-mole, new or existing NAIC groups are being tasked to consider the various regulatory issues that are popping up from insurance innovation....more
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
Certain “bad actors” who settle with the SEC may be subject to automatic disqualifications or collateral consequences under federal securities laws and regulations. The Commission, however, may grant a settling party’s...more
The NAIC and states are reviewing whether to flush those provisions of state anti-rebating laws that inhibit innovation in the insurance industry. The NAIC Unfair Trade Practices Act (#880) prohibits offering any premium...more
The NAIC Annuity Suitability Working Group (Suitability WG) spent the summer at the July 23, July 29, and August 3 Suitability WG meetings trying to get out of the parking lot and discussed several issues to frame up the...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
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
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, on June 5, announced that it would be exploring “modernization of the design, delivery and content of fund disclosures” in order “to improve the investor experience and help investors make more informed investment...more
At the 2018 NAIC Summer National Meeting, regulators continued their efforts to define the standard of care that applies to recommendations. This subject was discussed at both the Annuity Suitability (A) Working Group...more
On July 18, New York's Department of Financial Services (the "NY DFS") issued the final version of its Suitability and Best Interests in Life Insurance and Annuity Transactions Regulation (the "Suitability and Best Interest...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
During two weeks in April, two different courts — the Second Circuit and the New Jersey Superior Court — considered nearly identical allegations regarding variable products and reached diametrically opposed conclusions about...more