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Carlton Fields

FINRA Adds On to Its Annual Oversight Report - Building in RILA Sales Guidance for First Time

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In a section titled “Annuities Securities Products,” FINRA’s 2025 Annual Regulatory Oversight Report, issued on January 28, 2025, addresses regulatory obligations related to the sales of variable annuities (VAs) and...more

Carlton Fields

Expect Focus - Volume II, June 2018

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New York Pushes Mutual Fund Active Share Disclosure - New York’s Attorney General issued a report on its recent investigation of fees charged by actively managed equity mutual funds and a metric known as “Active Share.”...more

Carlton Fields

Back to the Future: 2017 [Expect Focus Life Insurance – December 2016]

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- Should Your Company Purchase Bitcoin to Pay a Cyber Ransom? - NAIC Draws Line in CFPB Sandbox - NAIC’s Big Data Task Force Sets Charges for 2017 - Broker-Dealers Can Hold Customers’ Initial Checks ...more

Carlton Fields

FINRA Fines Firms For Not Supervising L-Share Annuity Sales

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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

Carlton Fields

“Promptly Transmit” Redefined for Some Customer Checks

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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

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