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A Sea Change in RILA Regulation: Navigating the New Waters

On July 1, 2024, the Securities and Exchange Commission adopted a new registration framework for registered index-linked annuity (RILA) contracts. RILA contracts allow investors to allocate purchase payments to one or more...more

New SEC RILA Rules: Implementation Issues and Practical Considerations

On July 1, 2024, the Securities and Exchange Commission (SEC) announced new rules for registered index-linked annuities (RILAs) and registered market-value adjustment annuities (MVAs). The new rules will significantly impact...more

Insurers and Underlying Funds Sprint to Finalize Delivery Procedures for Tailored Shareholder Reports

Variable contract issuers and underlying funds are charging toward the finish line to finalize procedures for delivering upcoming semiannual “tailored” shareholder reports. The reports in this new format must be concise...more

Last Lap in SEC RILA Rulemaking: Critical Unresolved Issues

Congress directed the SEC to adopt a new registration statement for registered indexed annuities (RILAs) by the end of June. Several months ago, the SEC published its proposed registration statement and related rules. As we...more

Expect Focus - Volume I, January 2024

Funds Not Caged by SEC Names Rule Amendments: Roaming Room Remains - The SEC recently adopted amendments to its investment company “names” rule that apply to most SEC-registered funds, including underlying funds in which...more

SEC Folds on Swing Pricing for Money Market Funds: Odds Lengthen Against Swing Pricing for Other Fun

On July 12, the SEC adopted, on a 3–2 party line vote, so-called money market fund reforms. The reforms substitute a required redemption (liquidity) fee for proposed “swing pricing” for certain institutional money market...more

ETFs in Variable Contracts: A New Marketing Opportunity?

The Secure Act of 2022, in order to facilitate the use of exchange-traded funds (ETFs) as investment options under variable contracts, directs the Treasury Department to amend the governing look-through rules under applicable...more

Expect Focus - Volume II, May 2023

For broker-dealers distributing and selling variable annuities, examinations will test for compliance with Reg BI and FINRA Rule 2330 because both standards apply to variable annuity sales. Firms distributing and selling...more

SEC Relief for RILA Issuers to Use Statutory Financials: Has the Moratorium Been Lifted?

Innovative registered index-linked annuity (RILA) contracts have become a permanent fixture in the retirement savings marketplace. RILAs provide investors with a product that offers upside potential with downside protection,...more

Expect Focus - Volume I, January 2023

More than 25 years have elapsed since the SEC adopted Exchange Act Rule 17a-4(f) governing electronic recordkeeping by broker-dealers. In an effort to update the rule to reflect “technology neutral” concepts, the SEC adopted...more

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