As interest rates rise and a potential recession looms, we’ve seen a flight to quality as new entrants seek to participate in our fund finance market. While most deals on our books have just one lender and one fund as...more
Following North Dakota, New Mexico, and Washington’s actions in 2021, there is a renewed effort by states to freshen up their rebating provisions to allow value-added products and services. Kansas came alive first by...more
On April 26, 2022, the SEC’s Division of Examinations (“EXAMS”) issued a risk alert flagging certain notable deficiencies that it has observed related to advisers’ potential misuse of material non-public information (MNPI) in...more
This is the third installment in the series Nowotny Knows Squat. This series focuses on value added planning ideas that financial advisors and life insurance agents should introduce to their clients. In case, you haven't...more
The rebating drafting group of the NAIC’s Innovation and Technology (EX) Task Force (“Innovation TF”) has been busy all summer working on proposed changes to section 4(H) of the NAIC’s Unfair Trade Practices Act (UTPA). On...more
While everyone was working from home, the NAIC's Innovation and Technology (EX) Task Force (Innovation TF) was busy creating proposed new game rules on rebating. ...more
For decades, life insurance has been viewed as just providing benefits to those named as the beneficiary. As we enter the new decade, insurers are changing this narrative....more
Since mid-2018, the NAIC’s Innovation and Technology (EX) Task Force (Innovation TF) has been considering how state anti-rebating laws impede insurers and producers’ ability to offer innovative products and services to...more
The NAIC and states are reviewing whether to flush those provisions of state anti-rebating laws that inhibit innovation in the insurance industry. The NAIC Unfair Trade Practices Act (#880) prohibits offering any premium...more
Navigating the U.S. Healthcare Regulatory Landscape for Wearable Devices - Complex Environment Includes Key Federal Agencies FDA, FTC, OCR, CPSC, CMS, and OIG - The wearable device market is emerging as a key player...more
The practice of rebating has long been prohibited in nearly every state across the country. Despite this long-standing and widespread prohibition, the full scope of services that are and are not permissible under each state’s...more