TAKE A CHANCE ON ME! PART II - Embracing the Magic of Private Placement Life Insurance and Private Placement Variable Annuities
NOWOTNY KNOWS SQUAT! Part 2 Using PPLI and PPVA Annuities to Raise Assets Under Management and Sell More Life Insurance
A September report of the North American Securities Administrators Association (NASAA) on broker-dealer compliance with the SEC’s Regulation Best Interest (Reg BI) finds...more
FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more
Sales of fee-based annuities have soared in recent years. However, the financial planners and investment advisers that use them with clients may be unknowingly exposing themselves to future enforcement action from state...more
Every year the Financial Institution Regulatory Authority (FINRA) issues its “Report on FINRA’s Examination and Risk Monitoring Program.” The Report covers issues noted during the prior year’s exams and topics that examiners...more
On January 10, 2023, the Financial Industry Regulatory Authority, Inc. (“FINRA”) released its 2023 Report on FINRA’s Examination and Risk Monitoring Program (the “Report), available at: 2023 Report on FINRA’s Examination and...more
After years of relative silence related to variable annuity exchanges on the regulatory front, the U.S. Securities and Exchange Commission announced last week settled charges against RiverSource Distributors, Inc...more
On January 8, 2021, without admitting or denying the findings, VALIC Financial Advisors, Inc., (VALIC) entered into a settlement with FINRA Enforcement, through an Acceptance, Waiver and Consent (AWC) where the factual...more
On February 1, 2021, the Financial Industry Regulatory Authority (“FINRA”) released its “Report on FINRA’s Risk Monitoring and Examination Activities.” The Report combines two of FINRA’s long-standing reports: (a) the...more
As everyone is likely well aware, one of the principal changes that happened when FINRA retired the old suitability rule – NASD Rule 2310 – and replaced it with shiny new FINRA Rule 2111 back in 2012 was the broadening of the...more
FINRA’s report on its broker-dealer examination findings for 2018 features a substantial discussion of “Unsuitable Variable Annuity Recommendations.” This is in sharp contrast with FINRA’s 2017 report, which didn’t mention...more
FINRA’s reported enforcement actions as to certain variable annuity practices increased in 2018. For example, FINRA announced more than half a dozen settlements – via Letters of Acceptance, Waiver and Consent (AWCs) – for...more
From January through July 2018, the Financial Industry Regulatory Authority (FINRA) has continued its focus on variable annuities (VAs), particularly related to exchanges and multi-share class VAs. FINRA has thus far settled...more
Meet ZTE (well, meet them again. We’ve discussed them before), the massive Chinese electronics maker banned last month by the White House from using US-made components that could well be the “first casualty of the high-tech...more
In 2017, the Financial Industry Regulatory Authority (FINRA) ordered more than two times the restitution from the prior year, resulting in the fourth highest total of sanctions (fines combined with restitution and...more
In late 2017, FINRA pronounced in Regulatory Notice 17-30 that, "Beginning on October 1, 2018, unregistered persons cannot accept an order from a customer under any circumstances. ...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
For two years FINRA has made sales and marketing of L-Share variable annuities (VAs) a regulatory and examination priority. Not surprisingly, FINRA in November announced settled actions against eight broker-dealers, alleging...more
Soooooo . . . about that whole Brexit thing. A UK High Court has ruled that Britain’s EU withdrawal cannot move forward without the approval of Parliament, setting off more uncertainty and what’s expected to be a series of...more
MetLife, accused by regulators of misleading tens of thousands of customers about variable annuities—“a product that retirees seek out for safety,” will pay a $25 million dollar fine for its actions. It’s the second-largest...more
Below 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
As we discussed yesterday, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (OCIE) released its examination priorities for 2016 on January 11 (the “Examination Priorities”)....more
The SEC and FINRA recently extended relief originally granted to accommodate suitability reviews of deferred variable annuities, so that the relief is now also available for mutual funds, Section 529 plans, and other...more
FINRA opened 2015 with a lengthy and ambitious agenda of regulatory priorities. This year’s Regulatory and Examination Priorities Letter is much longer than those issued the last two years, and repeats many of those years’...more
In a case involving unsuitable variable annuity (VA) transactions, FINRA found that having good procedures and discovering improper conduct are not enough. A member firm must also ensure that it has adequate supervisory...more
As baby boomers continue to age, securities regulators focus on protecting the growing population of seniors and retirees. For example, the regulators are seeking to ensure that broker-dealers’ systems and procedures for...more