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
On March 23, 2020, the SEC issued an order (the “Order”) granting registered open-end funds and insurance company variable annuity separate accounts expanded capability to borrow from their affiliates to satisfy redemption...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
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
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
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
SEC staff in December issued a Guidance Update that provides significant flexibility regarding how mutual funds and variable annuities (VAs) reflect multiple charge structures in their SEC registration statements....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
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
William Kotapish, an Assistant Director in the SEC’s Division of Investment Management, recently stated that the SEC staff is prepared to recommend that the Commission adopt rules and forms authorizing a variable annuity...more