NAIC Training Compliance Reminder

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To date, more than half the states have adopted the National Association of Insurance Commissioners (NAIC) revisions to the Suitability in Annuity Transactions Model Regulation (#275). The revisions impose several new requirements on both producers and insurers, including new training.

Many training deadlines are soon approaching. To help you make sure you are in compliance with the state(s) where you do business, we want to remind you of state-specific requirements.  

State-specific requirements are shown below:

State Effective Date Best Interest Training Deadline Will Accept Reciprocal Training
If Licensed PRIOR to Effective Date1 If Licensed AFTER Effective Date
Alabama 1/1/2022 6/30/22 Prior to solicitation Yes
Arkansas 7/8/2021 1/1/20222 1/1/20222 Yes
Arizona 1/1/2021 6/30/2021 Prior to solicitation Yes
Connecticut 3/1/2022 8/31/2022 Prior to solicitation Yes
Delaware 8/1/2021 1/31/2022 Prior to solicitation Yes
Hawaii 1/1/2023 7/1/20231 Prior to solicitation Yes
Idaho 7/1/2021 12/31/2021 Prior to solicitation Yes
Iowa 1/1/2021 6/30/2021 Prior to solicitation Yes
Kentucky 1/1/2022 6/30/2022 Prior to solicitation Yes – non-resident producers only
Maine 1/1/2022 6/30/2022 Prior to solicitation Yes
Maryland 10/8/2022 4/8/2023 Prior to solicitation Yes
Michigan 6/29/2021 12/29/2021 Prior to solicitation Yes
Minnesota 1/1/2023 7/1/2023 Prior to solicitation Yes
Mississippi 1/1/2022 6/30/2022 Prior to solicitation Yes
Montana 10/1/2021 3/31/2022 Prior to solicitation Yes
Nebraska 7/1/2021 12/31/2022 Prior to solicitation Yes
New Mexico 10/1/2022 4/1/2022 Prior to solicitation Yes
North Carolina TBD3 TBD3 Prior to solicitation TBD
North Dakota 1/1/2022 6/30/2022 Prior to solicitation Yes
Ohio 2/14/2021 8/14/2021 Prior to solicitation Yes
Pennsylvania 6/20/2022 12/20/2022 Prior to the end of 1st license period4 Yes
Rhode Island 4/1/2021 9/30/2021 Prior to solicitation Yes
South Carolina 11/27/2022 11/27/2022 Prior to solicitation Yes
South Dakota 1/1/2023 6/30/2023 Prior to solicitation Yes
Texas 9/1/2021 12/31/2021 Prior to solicitation Yes
Virginia 9/1/2021 2/28/2022 Prior to solicitation Yes
Wisconsin 10/1/2022 4/1/2023 Prior to solicitation Yes
1 After expiration of the grace period, any producer that has not met the training requirement may not solicit or sell annuities until they complete the new 4-hour training or can show they are otherwise compliant via nonresident reciprocity rules.
2 Arkansas’ grace period applies to all producers. Beginning January 1, 2022, any producer that has not met the training requirement may not solicit or sell annuities until they complete the 4-hour training.
3 North Carolina has approved the rule by regulation but has not released the final rule or effective dates at this time. Athene is monitoring and will provide a more comprehensive update in the coming days.
4 New producers licensed on or after June 20, 2022, have until the end of the producer’s first license period to complete the training requirements.