News & Analysis as of

Regulatory Oversight Life Insurance Regulatory Requirements

Mitchell, Williams, Selig, Gates & Woodyard,...

2025 Arkansas Insurance Legislation Summary: Life

The 95th Arkansas General Assembly convened on January 13, 2025, and entered into an extended recess on April 16, 2025...more

Carlton Fields

NAIC Life and Annuity Illustration Subgroup and Suitability Working Group Construct More Guidance

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At the NAIC Spring National Meeting, the Illustration Subgroup and the Suitability Working Group reported that they are building out the following additions...more

McDermott Will & Emery

Insurance Regulators Continue Big Data Scrutiny

We previously reported on regulators’ increased attention to the use of big data systems, including external consumer data and information sources, algorithms and predictive models. Recent announcements in Colorado, Louisiana...more

Carlton Fields

Out of the Gate Fast

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Arizona jumped out front of the pack with the introduction of Senate Bill No. 1557, titled "Annuity Transactions; Requirements," which would amend Arizona's suitability requirements for annuity transactions. Senate Bill No....more

Carlton Fields

SEC Expands Manager-of-Managers Relief to Affiliated Sub-Advisers

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On May 29, 2019, the SEC granted an exemptive order to Carillon Series Trust and Carillon Tower Advisers Inc. (a Raymond James affiliate) to hire and replace affiliated and unaffiliated sub-advisers without shareholder...more

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SEC Now May Consider a Simultaneous Settlement Offer and Waiver Request

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Certain “bad actors” who settle with the SEC may be subject to automatic disqualifications or collateral consequences under federal securities laws and regulations. The Commission, however, may grant a settling party’s...more

Carlton Fields

Annuity Suitability Working Group Tries to Get Out of the Parking Lot

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The NAIC Annuity Suitability Working Group (Suitability WG) spent the summer at the July 23, July 29, and August 3 Suitability WG meetings trying to get out of the parking lot and discussed several issues to frame up the...more

Carlton Fields

Changes to the Index Product Illustration Requirements Are No Child’s Play

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The NAIC’s Annuity Disclosure Working Group and IUL Illustration Subgroup continue to chalk out changes to the Annuity Disclosure Model Regulation (Model) and Actuarial Guideline 49 (AG 49) to address index product...more

Carlton Fields

New Procedures for Mutual Fund and Insurance Product SEC Filings

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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

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SEC ‘Investor Experience Initiative’ Expressly Includes Variable Insurance Products

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The SEC, on June 5, announced that it would be exploring “modernization of the design, delivery and content of fund disclosures” in order “to improve the investor experience and help investors make more informed investment...more

Carlton Fields

As Students Return to School, Regulators Continue Their Study of the NAIC’s Suitability in Annuity Transaction Model Regulation

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At the 2018 NAIC Summer National Meeting, regulators continued their efforts to define the standard of care that applies to recommendations. This subject was discussed at both the Annuity Suitability (A) Working Group...more

Carlton Fields

New York Issues Final Life Insurance and Annuity Suitability and Best Interests Regulation

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On July 18, New York's Department of Financial Services (the "NY DFS") issued the final version of its Suitability and Best Interests in Life Insurance and Annuity Transactions Regulation (the "Suitability and Best Interest...more

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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

Which Thoroughbred Will Win the Standards of Care Derby?

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The NAIC and the State of New York continue racing as each is revising its suitability regulation to incorporate enhanced standards of care. Only time will tell which version will gallop to victory....more

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