NAIC Updates – June 2018

Model Regulation #275

The Annuity Suitability (A) Working Group of the NAIC Life Insurance and Annuities (A) Committee held an open meeting on Saturday, March 24, 2018 during the NAIC 2018 Spring National Meeting in Milwaukee, Wisconsin. The meeting centered on proposed revisions to the Suitability in Annuity Transactions Model Regulation #275 ("Model #275") which had been introduced at the NAIC 2017 Fall National Meeting and included a "best interests" standard designed to comport with U.S. Department of Labor's ("DOL") fiduciary rule. Model #275 was adopted to "set standards and procedures for suitable annuity recommendations, and to require insurers to establish a system to supervise recommendations so that the insurance needs and financial objectives of consumers are appropriately addressed." A recent federal circuit court decision has undermined the DOL fiduciary rule raising questions in the Working Group regarding the viability of its proposed revisions to