New NAIC Suitability Model Regulation Changes Coming Soon for Annuities Sold in Michigan, Idaho, Nebraska and Delaware

New NAIC Suitability Model Regulation changes coming soon for annuities sold in Michigan, Idaho, Nebraska and Delaware

Michigan, Idaho, Nebraska and Delaware have all adopted the new NAIC model regulation. Please refer to the dates below for effective dates of the various requirements for each state. These requirements apply to all new and existing financial professionals.

The biggest component of this regulation includes the adoption of the Best Interest Standard of Care, requiring financial professionals to act in the best interest of the consumer when recommending annuity products.

Form changes

This change will affect several existing forms, as well as the addition of a new form that will be required.

• The needs analysis forms were already updated for all fixed, indexed and income annuities to include a few additional questions pertaining to suitability. Submission guidelines for variable annuities remain unchanged.
• A new form, the Financial Professional Disclosure for Annuities (DD9583), will be required and available for all new fixed, indexed and income annuity applications signed on or after June 29 for Michigan, July 1 for Idaho and Nebraska, and August 1 for Delaware (required by the primary financial professional if a split case).

New state training requirements

While the product training requirement remains unchanged, the state training requirement has been expanded to include the new standard of conduct sales practices.

Financial professionals who have completed the original training requirement before the effective date, must complete either a new one-time 4-hour course, or an additional one-time 1-hour course. See chart below for effective dates. Financial professionals who obtain a life insurance license on or after the effective date must complete the new one-time 4-hour course before selling annuities. In other words, the old 4-hour NAIC Suitability Model Regulation Course no longer satisfies the annuity state training requirement in the states that adopt the new 2020 version of the NAIC Suitability Model Regulation.

All training vendors are working on adding both the new 1-hour and 4-hour training courses that meet the new 2020 regulation requirements. If you are completing this training via RegEd, the courses are titled Recommending Annuities Under the NAIC Best Interest Standard (Course 490) and Recommending Annuities Under the New NAIC Best Interest Standard – One Hour Update (Course 491). If training is not completed through Virtual University or RegEd, a certificate of completion must be sent to Sales Compensation Administration to prove training has been completed.