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Greetings, The August 2008 issue of FORC Alert is now available. We hope you find this information useful. If you have interested colleagues, please forward to them a link to the publication. Best regards, Kevin G. Fitzgerald Sign up to receive FORC Alerts (and Journals) via email.
Suicide Exclusion - The Arizona Department of Insurance has recently adopted an interpretation that the suicide exclusion for Universal Life Insurance Policies can not be used in connection with any increase in the death benefit for an existing policy. Per the Department of Insurance, the suicide exclusion provision is only applicable for two years from the date of the issue of the policy and cannot be applied to any subsequent increase in the death benefit of the underlying policy. J. Michael Low, Esq. - LOW & COHEN, PLLC, (602) 648-4040, mlow@lowcohen.com
SEC Issues Proposed Rule on Indexed Annuities - On June 15, 2008, the SEC issued a proposed new rule that would define the terms "annuity contract" and "optional annuity contract" under the Securities Act of 1933. The proposed rule is intended to clarify the status under the federal securities laws of indexed annuities, under which payments to the purchaser are dependent on the performance of a securities index. The proposed rule would apply on a prospective basis to contracts issued on or after the effective date of the rule. There is an exemption for insurance companies from filing reports under the Securities Exchange Act of 1934 provided that the securities are regulated under state insurance law, the issuing insurance company and its financial condition are subject to supervision and examination by a state insurance regulator, and the securities are not publicly traded. Comments Due: September 10, 2008. Michael J. Rothman - WINTHROP & WEINSTINE, P.A., (612) 604-6486, mrothman@winthrop.comHouse Financial Services Subcommittee Approves Three Insurance Regulatory Measures - On July 9, the House Financial Services Subcommittee on Capital Markets, Insurance and Government Sponsored Enterprises, chaired by Rep. Paul Kanjorski (D-PA), approved three insurance regulatory measures: (1) H.R. 5840, the Insurance Information Act of 2008 - Establishing the Office of Insurance Information within the Department of the Treasury to set federal insurance policy, particularly internationally, and preempt state laws inconsistent with such policy; (2) H.R. 5792, the Increasing Insurance Coverage Options for Consumers Act of 2008 - Amending the Liability Risk Retention Act of 1986 to cover risk retention groups offering commercial property insurance; and (3) H.R. 5611, the National Association of Registered Agents and Brokers Reform Act of 2008 - Re-establishing the National Association of Registered Agents and Brokers (NARAB) for the purpose of providing a national mechanism through which licensing, continuing education and other insurance producer qualification requirements and conditions can be adopted and applied on a multi-state basis. Copies of the Substitute Amendments adopted on each of the bills are available at the following Web page of the House Financial Services Committee: http://www.house.gov/apps/list/speech/financialsvcs_dem/mu070908.shtml Charles T. Richardson, Esq. - BAKER & DANIELS LLP, (202) 312-7487, crichardson@bakerd.com
U.S. Treasury Blueprint (or Footprint?) -
Genetic Information - Health Insurance Not in the DNA - Ending a 13-year debate, Congress has given final passage to the Genetic Information Non-Discrimination Act. GINA will prohibit utilization of genetic information in health insurance underwriting and in employment. Several states have similar laws, but coverage and standards are inconsistent from state to state. Federal agencies have 12 months to write interpretive regulations. President Bush signed the bill on May 21, 2008. U.S. Senate Committee Hearing Report: State of the Insurance Industry - The United States Senate Committee on Banking, Housing and Urban Affairs (“Committee”) held a hearing on July 29, 2008, to examine the current regulatory and oversight structure of the nation’s insurance industry. The Hearing, entitled “State of the Insurance Industry: Examining the Current Regulatory and Oversight Structure” was held to consider the impact of the regulatory structure on the insurance marketplace, industry participants, and policyholders. Fred E. Karlinsky, Esq. - COLODNY, FASS, TALENFELD, KARLINSKY & ABATE, P.A., (954) 492-4010/(954) 332-1749, fkarlinsky@cftlaw.com
Supreme Court Addresses Scope of Surplus Lines Regulation -
Appellate Court Upholds OIR Ban on Binding Arbitration -
Insurer Use of Credit Scoring Rule Still Pending; DOAH Order Issued - In February 2005, the Florida Office of Insurance Regulation ("OIR") proposed a Rule, 69O-125.005 Use of Credit Reports and Credit Scores by Insurers to prevent discrimination in the use of credit scores by insurers. This Rule would have imposed an affirmative burden on insurers to establish with OIR that any credit scoring methodology utilized did not “disproportionately affect” consumers based on race, color, religion, marital status, age, gender, income, national origin or place of residence. Some insurance industry trade associations challenged the proposed Rule in an administrative proceeding, arguing it would effectively ban the use of credit scores in the underwriting of insurance policies.
The Administrative Law Judge provided in the Order that this matter has been pending for an extended period of time and that it will either have to be moved toward a hearing or "go away." This Order, which may be viewed by clicking here, is the latest development on this Rule challenge. Fred E. Karlinsky, Esq. - COLODNY, FASS, TALENFELD, KARLINSKY & ABATE, P.A., (954) 492-4010/(954) 332-1749, fkarlinsky@cftlaw.com Governor Signs SB 2012 Relating to Insurance Policies: June 23 - On June 23, 2008, Governor Charlie Crist signed Senate Bill 2012 relating to Insurance Policies/Adjusters, Agents and PIP. The bill, sponsored by Senator Ted Deutch (D- Delray Beach), originally addressed long-term care issues. However, it was amended several times during the legislative process to include other insurance-related provisions. As passed, the bill amends the laws relating to public adjusters, the Florida Hurricane Catastrophe Fund, multiple-employer welfare arrangements, the Personal Injury Protection fee schedule, Citizen's Property Insurance Corporation, insurance agents, title insurance, self-insurance funds, and risk pooling for hospitals, among other provisions. The bill is effective July 1, 2008 unless otherwise provided. To view the bill text, click here. Fred E. Karlinsky, Esq. - COLODNY, FASS, TALENFELD, KARLINSKY & ABATE, P.A., (954) 492-4010/(954) 332-1749, fkarlinsky@cftlaw.comCitizens Board of Governors Announces $1.75 Billion in Pre-Event Financing; Chairman Douglas Retires, Jim Malone Appointed - Citizens Property Insurance Corporation (“Citizens”) announced at its June 19, 2008 Board of Governors meeting that it has secured pre-event financing of $1.75 billion for its high-risk account. This amount is in addition to the $1.6 billion bank credit line obtained for the Personal Lines Account and the Commercial Lines Account. The financing provides Citizens access to more than $20 billon of claims-paying capacity for future claims in its high-risk account. Citizens also completed the purchase of private reinsurance for the high-risk account for the mandatory co-payment required to access funds from the Florida Hurricane Catastrophe Fund in the event of disaster. The purchase of reinsurance in the high-risk account transfers over $450 million of potential risk and assessments from Citizens’ customers to the private insurance market. At the June 19, 2008 meeting, Citizens Board of Governors’ Chairman Bruce Douglas announced that he has decided not to seek reappointment to the Board. Appointments of all Board members expired on July 31, 2008. Florida Chief Financial Officer Alex Sink announced on July 25, 2008 the appointment of James R. Malone as Citizens’ new Chairman of the Board of Governors effective August 1, 2008. Fred E. Karlinsky, Esq. - COLODNY, FASS, TALENFELD, KARLINSKY & ABATE, P.A., (954) 492-4010/(954) 332-1749, fkarlinsky@cftlaw.com Governor Signs SB 648 and SB 2860 Into Law, Vetoes Insurance Capital Build-Up Incentive Program Funding - Governor Charlie Crist signed two insurance-related bills into law on May 28, 2008.
Although Governor Crist signed SB 2860 into law, he withheld approval of Section 16 of that bill, which provided an appropriation of $250 million for the Insurance Capital Build-up Incentive Program out of the surplus of Citizens Property Insurance Corporation. Fred E. Karlinsky, Esq. - COLODNY, FASS, TALENFELD, KARLINSKY & ABATE, P.A., (954) 492-4010/(954) 332-1749, fkarlinsky@cftlaw.comRequirements for Evidence of Workers' Compensation Coverage - The Florida Department Of Business And Professional Regulation, Board of Employee Leasing Companies Division has adopted Rule 61G7-10.0014: Requirements for Evidence of Workers’ Compensation Coverage, which addresses specific parameters associated with the requirement that employee leasing companies (“ELCs”) maintain workers compensation coverage. The Rule provides that all applicants for ELC licensure and licensees seeking renewal of their Florida licenses are required to file evidence of workers’ compensation coverage for all leased employees with the Board of Employee Leasing (“Board”). In addition, evidence must be submitted to the Board that all of the employee leasing company’s obligations concerning payment of workers’ compensation insurance premiums for leased employees have been fulfilled. To view the Rule text, click here. Florida Workers Compensation Joint Underwriters Association (FWCJUA) Operations Manual Revised -
Fred E. Karlinsky, Esq. - COLODNY, FASS, TALENFELD, KARLINSKY & ABATE, P.A., (954) 492-4010/(954) 332-1749, fkarlinsky@cftlaw.com Domestic Insurer Securities Custody Agreements - The Florida Office of Insurance Regulation has adopted the final version of the following Rules applicable to custody of securities for domestic insurance companies: 69O-143.042: Custody Agreement; Requirements (1) A domestic insurance company may, by written agreement with a custodian, provide for the custody of its securities with that custodian. These securities may be held by the custodian or its agent or in a clearing corporation. (2) Any such agreement must be in writing and authorized by a resolution of the Board of Directors of the insurance company or other authorized committee. The terms of the agreement must incorporate definitions prescribed in Rule 69O-143.041 Definitions. Fred E. Karlinsky, Esq. - COLODNY, FASS, TALENFELD, KARLINSKY & ABATE, P.A., (954) 492-4010/(954) 332-1749, fkarlinsky@cftlaw.com Impact of SB 2860 on Citizens Property Insurance - Senate Bill 2860 was signed into law on May 28, 2008, with the exception of Section 16 which would have transferred $250 million from Citizens to the General Revenue Fund for the 2008 Insurance Capital Build-Up Incentive Program. As signed, SB 2860 includes the following provisions that will directly impact Citizens: Rate freeze—Requires Citizens to make actuarially-sound rate filings beginning July 15, 2009 for all personal and commercial lines of business, which take effect no later than January 1, 2010. Note: This extension prohibits implementation of the screened enclosure exclusion and appropriately-priced optional buyback program until the freeze is lifted. Homestead vs. non-homestead—Eliminates the distinction between homestead and non-homestead properties for assessment purposes. Streamlined assessments—Eliminates multi-layered assessments on policyholders and instead requires: surcharges of up to 15 percent of the policy premium for 12 months on all Citizens policies, whether collected upon issuance or renewal; an assessment against insurers of up to 6 percent of the policy premium or 6 percent of the remaining deficit, which may be recouped from all assessible policyholders (excluding Citizens policyholders) if the first surcharge is not enough; and funding of any remaining deficit through multi-year emergency assessments of up to 10 percent of policy premiums or 10 percent of the remaining deficit, whichever is greater. Eligibility of higher-valued homes—Increases the maximum allowable replacement cost of a residence to be eligible for coverage with Citizens in the High Risk Account from $1 million to $2 million. Code-plus—Eliminates the code-plus building standard provision in current law affecting properties constructed on or after January 1, 2009 located within 2,500 feet of the coastal construction control line. Also, Citizens will be replacing its outdated wind-only policy form with industry-standard ISO forms. Fred E. Karlinsky, Esq. - COLODNY, FASS, TALENFELD, KARLINSKY & ABATE, P.A., (954) 492-4010/(954) 332-1749, fkarlinsky@cftlaw.com Citizens Adds Rules to Disputed Claims Appraisal Policy Form - Citizens Property Insurance Corporation (“Citizens”) has made changes to its Disputed Claims Appraisal policy form for the disputed claims appraisal process following a loss. The changes include:
Fred E. Karlinsky, Esq. - COLODNY, FASS, TALENFELD, KARLINSKY & ABATE, P.A., (954) 492-4010/(954) 332-1749, fkarlinsky@cftlaw.com 2008 Florida Legislative Changes Impacting Life and Health Insurers - HB 535 - Certain changes to Florida law were enacted during the 2008 Regular Session of the Florida Legislature by the passage of House Bill 535. Among other provisions, House Bill 535 has amended Section 627.4236, F.S. to revise the meaning of “bone marrow transplant” to include non-ablative therapy with curative or life-prolonging intent. It also amends Section 627.657, F.S. to specify that identification cards of group health insurance policies and Outline of Coverage documents must include certain minimum information. Fred E. Karlinsky, Esq. - COLODNY, FASS, TALENFELD, KARLINSKY & ABATE, P.A., (954) 492-4010/(954) 332-1749, fkarlinsky@cftlaw.com
Georgia General Assembly Passes Insurance Bill - Includes UM "Stacking" Provision and Converts Georgia to "File-and-Use" System for Auto Insurance - The Georgia Governor signed Senate Bill 276 into to law on May 14, 2008. The new legislation gives drivers the option to “stack” or supplement their uninsured motorists auto insurance policy provisions on top of the at-fault driver’s auto insurance policy, providing additional coverage for accidents involving at-fault drivers who have little or no auto insurance. The new law also converts Georgia to a “file-and-use” rate system for private passenger motor vehicle insurance, for coverage levels other than the mandatory minimum limits, eliminating the prior approval requirement of the Georgia Insurance Commissioner under Georgia law. The stacking provision will become effective on January 1, 2009 and the file-and-use provision will become effective on October 1, 2008. Brian T. Casey, Esq. - LOCKE LORD BISSELL & LIDDELL LLP, (404) 870-4638, bcasey@lockelord.comGeorgia General Assembly Passes Insurance Bill - Provides Insurer, Employer and Individual Tax Incentives for High-Deductible Health Plans - The Georgia Governor signed House Bill 977 into law on May 7, 2008, the new legislation which becomes effective January 1, 2009, grants preferential Georgia premium tax treatment to high deductible health insurance plans. The new law exempts high deductible health insurance plans from both the state and any local insurance premium tax; creates a Georgia income tax credit of $250 per employee enrolled in a high deductible health insurance plan for employers; and creates a Georgia income tax deduction for high deductible health insurance plan premiums for individual Georgia taxpayers. The fiscal note for the predecessor bill to House Bill 977 indicates that the tax preferences are expected to total $24.9 million in 2010, the first full year of implementation, with the majority of the tax preferences (67%) flowing to insurers due to the exemption from the insurance premium tax. Limitation on Liability - Insurance Contract Not Reformed - Denial of partial summary judgment affirmed in suit by a passenger and his wife against transport company for injuries sustained by passenger while in transport company’s van, which was involved in an accident while transporting the passenger. Plaintiffs had claimed that the liability coverage contained in transport company’s commercial auto insurance policy should be reformed to comply with the $5M in liability coverage that is federally mandated for motor carriers which engage in interstate transport of passengers. The court rejected the Plaintiffs’ argument since reformation “is not available for the purpose of making a new and different contract for the parties, but is confined to establishment of the actual agreement” holding that no authority or public policy requires insurers to provide ex post facto coverage in amounts, which exceed what was actually contracted for and purchased by the insured. Turner v. Gateway Ins. Co., A08A0635 (04/03/08), 08 FCDR 1259. Brian T. Casey, Esq. - LOCKE LORD BISSELL & LIDDELL LLP, (404) 870-4638, bcasey@lockelord.com
Clarity for Standards of Review - The Illinois Supreme Court in Cinkus v. Village of Stickney Municipal Officers Electoral Board, 886 N.E.2d 1011 (2008) clarified the three standards of review for administrative decisions. The standards are question of law, question of fact, and mixed question of law and fact. The Supreme Court admitted that its past distinctions have not been completely clear in applying the three standards. This case also affirms the procedural default rule which is that if a party fails to raise an issue at the administrative level, the issue is waived at judicial review. Cinkus is an important case for regulatory practitioners because it helps guide the practioner as to what standard to argue at review, and serves as a reminder to raise all issues, whether the agency has jurisdiction to decide the issue or not, at the administrative level. Steve W. Kinion, Esq. - ZACK STAMP, LTD, (217) 525-0700 ext. 108, skinion@601w.com
Fraudulent Insurance Acts - The 2008 Regular Session of the Louisiana Legislature has added some additional activities that constitute “fraudulent insurance acts” under the Louisiana Insurance Code. The new fraudulent insurance acts include manufacturing, selling, distributing, presenting or causing to be presented a fraudulent proof of insurance card or document, and altering a legitimate proof of insurance card or document. Such acts are felonies under the Code, and are punishable by imprisonment, with or without hard labor, of up to five (5) years, a fine of up to five thousand dollars ($5,000), or both, as well as payment of restitution to the victim company. Van R. Mayhall, III - Breazeale, Sachse & Wilson, LLP, (225) 381-3169, vm@bswllp.com and Van R. Mayhall, Jr., Esq. - BREAZEALE, SACHSE & WILSON, L.L.P., (225) 381-8009, vrm@bswllp.com Insure Louisiana Incentive Program: Third Invitation for Grant Applications - The Louisiana Legislature has authorized a “third invitation” for grants under the Insure Louisiana Incentive Program. The Insure Louisiana Incentive Program is a grant program established by the Legislature in 2007 that, pursuant to Regulation 82 of the Louisiana Department of Insurance, encourages insurers to participate in the voluntary property insurance market in Louisiana for the purposes of increasing the availability of property insurance and competitive pressure on insurance rates, and reducing the volume of business written by the Louisiana Citizens Property Insurance Corporation. The Program started with $100 million in available incentive money, but only approximately $40 million in grants were awarded to insurers in the first two “invitations” for grant applications. Although the Department has not yet had time to set out the standards and procedures for the third invitation for grant applications, it should parallel the previous two invitations, and draw from the remaining $60 million. Any funds remaining after the third invitation will be used to fund the newly-created Homeowner Policy Premium Assistance Program created by the Legislature. Van R. Mayhall, III - Breazeale, Sachse & Wilson, LLP, (225) 381-3169, vm@bswllp.com and Van R. Mayhall, Jr., Esq. - BREAZEALE, SACHSE & WILSON, L.L.P., (225) 381-8009, vrm@bswllp.com
Minnesota Enacts Insurance Good-Faith Law - The Minnesota Legislature passed and the Governor signed into law (ch. 208) the insurance standard of conduct (first party good faith) insurance claims practices regulation. The new law requires insurers to act in good faith in connection with an insured's claim under an insurance policy and provides remedies for noncompliance. The law is effective August 1, 2008, and applies to causes of actions for conduct occurring on or after that date. Michael J. Rothman - WINTHROP & WEINSTINE, P.A., (612) 604-6486, mrothman@winthrop.com
Bankruptcy Court Dismisses Chapter 15 Adversary Proceeding - In what appears to be a case of first impression, the United States Bankruptcy Court for the Southern District of Mississippi has dismissed an adversary proceeding filed in the Chapter 15 proceeding of Condor Insurance Limited (In Official Liquidation), an entity primarily involved in the reinsurance business which previously had been subject to a winding up order of the Eastern Caribbean Supreme Court in the High Court of Justice, St. Christopher and Nevis, Nevis Circuit. Liquidators appointed by the Nevis Court filed the adversary proceeding seeking to recover property valued at $313,000,000 as of 2005 asserting that Nevis law entitled them to avoid transfers of the property or to obtain equivalent damages. The Bankruptcy Court held that because a related, non-Chapter 15 proceeding was not pending, subject matter jurisdiction was lacking and that the liquidators had not presented any authority in a Chapter 15 context to support the use of foreign avoidance law when United States avoidance law is not available. The liquidators have appealed. Case No. 07-51045. Robert B. House, Esq. - WATKINS LUDLAM WINTER & STENNIS, P.A., (601) 949-4830, rhouse@watkinsludlam.com and David L. Martin, Esq. - WATKINS LUDLAM WINTER & STENNIS, P.A., (601) 949-4901, dmartin@watkinsludlam.comExpedited Review of Form and Rate Filings - Commissioner of Insurance Mike Chaney promulgated Regulation 2008-2 establishing an expedited form and rate review process for all life, credit life, annuity, and accident and health contracts effective August 1, 2008. The regulation implements legislation passed in the 2008 Regular Session enabling companies to elect the expedited review process and pay the actuarial fees associated with review and approval of forms. The expedited review process is designed to provide companies with objections, approval or disapproval of each form within five business days of receipt by the actuary.
NC Short Session Ends -
New York Changes Late Notice Law to Require An Insurer to Prove Prejudice -
Anti-STOLI Law - Effective Sept. 11, 2008 - Ohio's new anti-STOLI law, Am. Sub. H.B. 404, has been signed into law and will take effect on Sept. 11, 2008. The law includes a prohibition on marketing or issuing STOLI, and a five-year "waiting period" before settlement of policies with STOLI characteristics. These central provisions of the law are based on concepts developed by the NAIC and NCOIL. The five-year waiting period, though based on the NAIC Model, uses alternative wording. Ohio legislators also enacted some unique provisions, including new requirements on insurers issuing life insurance in Ohio. First, applications for life insurance must include questions intended to identify STOLI transactions. The Insurance Department will issue a rule implementing this, and compliance will be required 12 months after the rule is final. Second, insurers issuing life insurance in Ohio will be required to file with the Department a description of their anti-STOLI efforts. Filing will be done electronically, in a format to be prescribed by the Department. The filings will be confidential. The Ohio law also includes provisions designed to help insurers detect STOLI. To motivate "transparency", the law provides that: (1) any premium finance agreement that is not disclosed to the issuing insurer within 30 days of execution is unenforceable; (2) any contract or agreement entered into in furtherance or aid of a STOLI transaction is void and unenforceable; and (3) a trust, LLC, LLP or other entity created as part of a STOLI transaction violates Ohio's insurable interest law. Faith M. Williams, Esq. - BRICKER & ECKLER LLP, (614) 227-2374, fwilliams@bricker.com
Ohio Department of Insurance Appoints New Chief Legal Counsel -
Insurance Development Position Created - The Ohio Department of Development will soon have a senior staff person responsible for "growing and strengthening" the insurance and banking industries in the State. State Rep. Jim Raussen has been appointed to the new position, and will report to the Lt. Governor, who also holds the post of Director of the Dept. of Development. Raussen, who has worked in the insurance industry, will resign his House seat and move into the new position in mid-August. Insurance Director Hudson is expected to work closely with Raussen on his efforts related to the insurance industry. Faith M. Williams, Esq. - BRICKER & ECKLER LLP, (614) 227-2374, fwilliams@bricker.com
New Deputy Commissioner -
Amendment to Insurance Regulation 110 -
Four Department Bills Enacted by 105th General Assembly - Marking a major achievement for Commissioner Leslie Newman, four significant bills --developed by the Tennessee Department of Commerce and Insurance and refined through the Department's active collaboration with industry participants -- were enacted by the 105th Tennessee General Assembly and signed by Governor Phil Bredesen. The new laws promote uniformity with other states and enhance TDCI's authority in four significant areas: (1) unfair trade and unfair claims settlement practices (the Tennessee Unfair Trade Practices and Unfair Claims Settlement Procedures Act of 2009, Pub. Ch. 1079), (2) producer licensing (Pub. Ch. 1192), (3) charitable gift annuities (the Tennessee Charitable Gift Annuity Act of 2008, Pub. Ch. 831), and (4) long term care insurance(Pub. Ch. 1058). T. Stephen C. Taylor, Esq. - BASS, BERRY & SIMS, PLC, (615) 742-7758, staylor@bassberry.com and Robins H. Ledyard, Esq. - BASS, BERRY & SIMS, PLC, (615) 742-6259, rledyard@bassberry.comRule on Annual Audited Financial Reports Subject of Rulemaking Hearing - On August 16, the Tennessee Department of Commerce and Insurance held a rulemaking hearing to review its proposed rule on Annual Audited Financial Reports. The proposed rule, which is based on the NAIC Model Regulation #25 (Annual Financial Reporting), amends existing Chapter 0780-1-65 to require most Tennessee licensed or authorized insurers to implement procedures for auditor independence, corporate governance and internal control over financial reporting which track those required of public companies pursuant to the federal Sarbanes-Oxley Act of 2002. T. Stephen C. Taylor, Esq. - BASS, BERRY & SIMS, PLC, (615) 742-7758, staylor@bassberry.com and Robins H. Ledyard, Esq. - BASS, BERRY & SIMS, PLC, (615) 742-6259, rledyard@bassberry.comTDCI Issues Three Proposed Rules on Variable Life and Annuity Products - Three proposed rules regulating variable life and annuity contracts were the subject of a Tennessee Department of Commerce and Insurance hearing on August 15. As proposed, new Chapter 0780-1-11 provides standards for disclosure of minimum information to consumers about annuity contracts, new Chapter 0780-1-16 establishes a broad regulatory scheme for variable life insurance policies issued in Tennessee, and amended and restated Chapter 0780-1-17 sets forth comprehensive requirements for the sale, issuance and delivery of individual and group variable annuity and variable life contracts in the state. T. Stephen C. Taylor, Esq. - BASS, BERRY & SIMS, PLC, (615) 742-7758, staylor@bassberry.com and Robins H. Ledyard, Esq. - BASS, BERRY & SIMS, PLC, (615) 742-6259, rledyard@bassberry.com
Annuity Sales Supervision Advisory Committee Reviews Proposed Regulations -
For updated information regarding the Committee's activities as well as downloadable copies of related materials on the draft of proposed regulations, visit the Committee's Web site, at http://oci.wi.gov/advcoun/anncomm.htm. |
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