News & Analysis as of

Insurance Industry No-Action Letters

Eversheds Sutherland (US) LLP

SEC grants no-action relief to delay payment from variable insurance contracts to protect vulnerable adults in cases of suspected...

Recently, in response to a request from the Committee of Annuity Insurers, the staff in the Chief Counsel's Office of the Securities and Exchange Commission's (SEC) Division of Investment Management issued a no-action letter...more

Vedder Price

Practice Pointer: Informal Guidance from the SEC Staff Regarding Rule 30e-3’s Transition Period Requirements for Variable...

Vedder Price on

The staff of the Securities and Exchange Commission (SEC) has informally provided Vedder Price with key interpretive guidance clarifying the transition period disclosure requirements for issuers of variable insurance products...more

Carlton Fields

Broker-Dealers Can Hold Customers’ Initial Checks

Carlton Fields on

A recent SEC no-action letter gives broker-dealers more time to perform suitability and other reviews when opening certain customer accounts. The firms requesting the letter were affiliated with three different insurance...more

Morgan Lewis

SEC Staff Issues No-Action Letter on Index Fund Investments in Insurance Companies and Securities Related Businesses

Morgan Lewis on

SEC staff expands upon prior no-action positions to permit funds that track a third-party index to invest in insurance companies and securities related businesses beyond the limitations set forth in Sections 12(d)(2) and...more

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