In a letter to Jolie H. Matthews, Senior Health and Life Policy Counsel for the National Association of Insurance Commissioners (NAIC), CFA is encouraging the withdrawal and revision of NAIC's  proposed “Suitability and Best Interest Standard of Conduct in Annuity Transactions Model Regulation.” As currently drafted, the proposal offers only limited improvements over the existing regulations governing annuities transactions. It falls well short of the true “best interest” standard that is needed to adequately protect consumers from the harmful impact of conflicts of interest in this market. It also fails to advance the goal of creating a uniform standard of conduct across all types of investment accounts and investment products.  The current proposal should be extensively revised to address these shortcomings.

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