112619F_FACC Comment Letter with Proposed Clarifications

The Fixed Annuity Consumer Choice Campaign has been working hard to improve the NAIC best interest proposal for the benefit of independent agents.  We have advocated changes to make the rule more objective in its requirements and more practical from an implementation and compliance standpoint.

The primary interest of FACC is ensuring any revisions to the model regulation adopting a best interest standard will ultimately be workable for the independent distribution channel consisting of insurance agents, marketing organizations, and carriers who offer fixed individual annuities to American consumers.  We believe independent producers and marketing organizations are essential to ensure consumers continue to have the widest array of options possible for retirement savings services and products and also avoid unnecessary disruption in the financial services marketplace to the detriment of independent producers.