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Insurance Industry Life Insurance Financial Industry Regulatory Authority (FINRA)

Orrick, Herrington & Sutcliffe LLP

FINRA fines annuity and fund distributor for causing payment of transaction-based compensation to unregistered entity

On July 8, FINRA accepted a firm’s Letter of Acceptance, Waiver, and Consent imposing a censure and a $300,000 fine. The firm is a wholesale distributor of variable insurance products and mutual funds. Between March 2018 and...more

Bressler, Amery & Ross, P.C.

State Regulation of Annuity Suitability and the Best Interests

Suitability in the sale of annuity products has been a topic of state regulation since at least 2003 - well before the federal focus on “Best Interest.” State insurance regulators have overseen the sale of annuities to ensure...more

Carlton Fields

Expect Focus - Volume II, May 2023

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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

Carlton Fields

FINRA Targets Variable Annuity Practices

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FINRA’s reported enforcement actions as to certain variable annuity practices increased in 2018. For example, FINRA announced more than half a dozen settlements – via Letters of Acceptance, Waiver and Consent (AWCs) – for...more

Carlton Fields

FINRA Requires Order Taker Registration

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In late 2017, FINRA pronounced in Regulatory Notice 17-30 that, "Beginning on October 1, 2018, unregistered persons cannot accept an order from a customer under any circumstances. ...more

Carlton Fields

Expect Focus - Volume IV, December 2017

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EXPECTFOCUS is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more

Carlton Fields

Expect Focus - Volume I, March 2017

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Regulators Demand Third-Party Risk Management - While third-party risk management has been a required component of an effective enterprise risk management program for many years, the topic is receiving elevated attention...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

What’s Your Game Plan? Offensive or Defensive: Playing to Your Strengths [Expect Focus – October 2016]

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- AXA Prevails at First Post-Jones v. Harris Excessive Fee Trial - Potential Secondary Effects of Regulatory Examinations: Evidentiary Issues and Preclusion in Parallel Litigation - On The Horizon: Global...more

Carlton Fields

Are You Prepared for Disruption? New regulations, new challenges and opportunities [Expect Focus – Vol. II, July 2016]

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- Fed Takes First Steps Toward Setting Capital Requirements for Some Insurers - New Wave of COI Rate Increase Lawsuits Hits the Industry - STOLI Policies Cancelled, Insurers Retain Premium -...more

Carlton Fields

For Life Insurers and Agents – A Summary of Predicted Litigation Under the DOL’s Proposed Fiduciary Rule

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The Department of Labor’s recent Proposed Rule (the “Proposal”), which defines the term “fiduciary” as it applies to persons who provide “investment advice” to ERISA plans and IRAs, will impact the likelihood and severity of...more

Carlton Fields

The Big Deal About Big Data: What Life Insurers Must Know

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Big data and predictive analytics, which forecast future outcomes based on past occurrences, allow companies to examine large stores of data and uncover patterns that can be used to gain a competitive advantage. Long-used in...more

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