Modernizing The Variable Contract Disclosure Regime
By Stephen Roth, Thomas Bisset, Dodie Kent and Frederick Bellamy ( December 11, 2018, 4:00 PM EST) -- The U. S. Securities and Exchange Commission recently proposed a new disclosure framework for SEC-registered variable annuity contracts and variable life insurance policies (together, variable contracts) that reflects almost a decade of major insurance industry (and SEC staff) efforts to develop a more modern and effective regime for variable contract prospectus disclosure. Among other things, proposed Rule 498A would permit (but not require) the use of summary prospectuses for variable contracts, with additional information available to investors online. To help investors make informed investment decisions, the SEC's proposal uses a layered disclosure approach similar to what has been in place for mutual funds. It is designed to provide investors with key information relating to the contract's terms, benefits and risks in a concise and more reader-friendly presentation, with access to more detailed information available online, or delivered in paper or electronic format on request. . . .
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