News & Analysis as of

Securities and Exchange Commission (SEC) Consumer Insurance Products

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

Carlton Fields

FINRA Corporate Financing Rule Amendments Bring Clarity for Insurance Products

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The SEC has approved amendments to FINRA’s corporate financing rule. The purpose of the rule is to allow FINRA to determine that public offering terms and conditions are not unfair, unreasonable, or inconsistent with FINRA...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

Reg BI Compliance Countdown: T-Minus Six Months

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As the June 30, 2020, compliance date approaches, broker-dealers are taking steps to implement Regulation Best Interest (Reg BI), which establishes a new standard of conduct when making recommendations to retail customers of...more

Robins Kaplan LLP

Financial Daily Dose 12.11.2019 | Top Story: US and China Hint at Tariff Delay to Help Ease Phase One Negotiations

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U.S. and Chinese trade negotiators are “laying the groundwork for a delay of a fresh round of tariffs set to kick in on Dec. 15” as the countries continue to work through how a Chinese promise to make huge ag purchases from...more

Carlton Fields

Multiple Plaintiffs Take Shot at SEC Regulation Best Interest

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The Securities and Exchange Commission’s Regulation Best Interest faces a bumpy road in the wake of recent lawsuits challenging the appropriateness and effectiveness of the rule....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

New Procedures for Mutual Fund and Insurance Product SEC Filings

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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

Carlton Fields

SEC Open to Modern Communications by Advisers

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The increasingly widespread use and acceptance of various types of online communications have made it more attractive — for both firms and clients — to conduct business online, while at the same time making it more doubtful...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

Carlton Fields

Parent Company Guarantees of Annuities

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Rule amendments proposed in October by the SEC could impact insurers whose obligations under certain types of annuity contracts have been guaranteed by the insurers’ affiliates....more

Carlton Fields

Is It Time to Revisit SEC’s Ban on “Forced” Arbitration Provisions?

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The SEC has long refused to allow companies to go public with bylaws or other governing documents that would require shareholders to arbitrate federal securities law claims against the company. ...more

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