WHERE HAVE YOU GONE, CHIP HILTON?
Somewhere Over the Rainbow
Investment Management Roundtable Discussion – Personal Estate Planning
On August 7, 2025, the National Association of Insurance Commissioners’ Annuity Suitability (A) Working Group issued draft safe harbor regulatory guidance with a comment period that ends on September 22, 2025. The draft...more
The DOL’s fiduciary regulation was scheduled to become effective this September 23. The exemptions were scheduled to become partially effective this September 23 and fully effective September 23, 2025....more
On April 25, 2024, the Department of Labor published its final regulation defining fiduciary status for investment advice and the related exemptions—PTE 2020-02 and 84-24. The exemptions provide relief from prohibited...more
To date, 27 states have adopted rules that follow the Suitability in Annuity Transactions Model Regulation issued by the National Association of Insurance Commissioners (NAIC). Recent additions reflected in the following...more
The Department of Labor’s “Fiduciary Rule,” PTE 2020-02: The FAQs - Key Takeaways - ▪️ The DOL has issued FAQs that generally explain PTE 2020-02 and the expanded definition of fiduciary advice. ▪️ In FAQ 18, the DOL...more
In the span of the last five months, the Securities and Exchange Commission (SEC) and its staff have issued two statements, a risk alert and an exam priorities roadmap, all of which address digital assets in full or in part....more
It appears that the SEC has initiated a “sweep” examination to inquire into the sales practices applicable to retirement plans for teachers and state and local government employees. We understand that multiple SEC regional...more
Broker-dealers selling annuity products in New York will soon need to comply with new best interest requirements imposed by New York’s amended Insurance Regulation 187. These requirements, which will take effect for annuities...more
In June, we circulated our fifth article on the continuing saga regarding the standard of conduct for sales of securities and annuities — and the efforts of federal and state regulators to impose new conditions on the...more
During the past two years, we have written about potential litigation arising under the Department of Labor’s, first proposed, then adopted fiduciary rule. In the first of those articles, when the Rule was initially proposed,...more
The U.S. Department of Labor (DOL) scored an initial victory in what is sure to be a long legal battle over the so-called "fiduciary rule." Judge Randolph D. Moss of the U.S. District Court for the District of Columbia issued...more