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Expect Focus - Volume IlI, September 2024

Gone With the Wind? Closed-End Funds Risk Extinction - Shares of SEC-registered closed-end funds (CEFs) have long held significant potential advantages for some investors. For example, unlike shares of mutual funds...more

Mutual Funds vs. Collective Investment Fund: Equal Investor Protection on the Horizon?

For more than a year, SEC Chair Gary Gensler has, in some public forums, been mentioning concerns about gaps in the regulation of collective investment funds (CIFs), as compared to that of registered open-end investment...more

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

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

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

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

NAIC Proposes Actuarial Guidelines for Index-Linked Variable Annuities

On July 25, 2022, the Index-Linked Variable Annuity (A) Subgroup of the NAIC’s Life Insurance and Annuities (A) Committee issued for public comment an exposure draft of proposed actuarial guidelines for index-linked variable...more

SEC Limits Need for Substitution Applications

On February 23, the Securities and Exchange Commission issued a statement setting forth a “no-action” position regarding when substitutions by an insurance company of mutual funds held in a variable separate account may be...more

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