WHERE HAVE YOU GONE, CHIP HILTON?
Somewhere Over the Rainbow
Investment Management Roundtable Discussion – Personal Estate Planning
Builder of Investment Models Deviates From Blueprints Employee’s Rogue Remodeling Costs Builder Plenty - The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered...more
Contingent deferred annuities (CDAs) represent an interesting approach to securing lifetime income but have struggled for recognition in the marketplace since their introduction more than a decade ago. Recent developments,...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
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
The issue over the Fiduciary Rule, and whether it will be implemented, revised, vacated, forgotten, etc. has been ongoing. In March 2018, the Fifth Circuit Court of Appeals ruled in favor of several business groups who...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 Tenth Circuit recently affirmed the Department of Labor’s authority to impose new conditions for exemption from prohibited transaction rules with respect to the sale of annuity contracts. The case related to the...more
As reported in our November 28 client alert, the National Association of Insurance Commissioners’ (NAIC) Annuity Suitability Working Group (Suitability WG) circulated the proposed Suitability and Best Interest Standard of...more
For the past several months, we have written about potential litigation issues under the “revised temporary” DOL Rule involving the offer and sale of annuities in the IRA market. This article continues that discussion. ...more
For the past several months, we have written about potential litigation issues under the “revised temporary” DOL Rule involving the offer and sale of annuities in the IRA market. This article continues that discussion. Recall...more
Last month, we wrote about potential litigation issues under the “revised temporary” DOL Rule involving the offer and sale of annuities in the IRA market. This paper continues that discussion. I emphasize to the reader that...more
Many mutual funds implement their investment strategies through "multi-manager" (also called "manager of manager") arrangements, particularly funds used to support variable life insurance and annuity products. Among other...more
Previously, I wrote about potential litigation under the Department of Labor’s then proposed fiduciary rule (see Expect Focus, Vol. II, 2015). I predicted the following as to sales of index annuities to IRAs if the rule was...more