CAI News and Memoranda

01.03.14 Committee Comment Letter on FINRA Proposal to Revise Form BR
11.06.13 Committee Comment Letter to NAIC Separate Account Risk Working Group
09.17.13 Committee Comment Letter on SEC Money Market Fund Proposals
09.13.13 2013 Gallup Survey of Owners of Individual Annuity Contracts
08.07.13 Committee Comment Letter on Lifetime Income Disclosure
07.05.13 Committee Response to SEC Request for Information on Duties of Brokers, Dealers and Investment Advisers
06.21.13 Committee Request for Interpretive Guidance on Lost Securityholders
05.22.13 Committee Request for Transition Relief on NII Tax Information Reporting
04.15.13 Committee Comment Letter to Ways and Means Committee
03.25.13 Committee Comment Letter on Insulated Separate Account Proposal
03.05.13 Committee Comment Letter on Recruitment Compensation Practices
02.15.13 Committee Comment Letter on FINRA BrokerCheck Rule 2267
11.21.12 Committee Comment Letter on Municipal Advisors
11.20.12 2012-13 IRS-Treasury Priority Guidance Plan
10.31.12 Committee Comment Letter to SEC and CFTC on Stable Value Contracts Study
08.20.12 Committee Comment Letter to Consumer Financial Protection Bureau on Senior Financial Exploitation
07.19.12 Committee Comment Letter on FINRA Fees
05.03.12 Committee Comment Letter on Proposed QLAC Regs.
05.01.12 Committee Comment Letter on IRS Business Plan
04.27.12 Committee Comment Letter on FINRA BrokerCheck
04.17.12 Supplemental Committee Comment Letter on Proposed Amendments to Broker-Dealer Auditing Standards
04.16.12 Committee Comment Letter on 81-100 Group Trusts
02.23.12 Committee Comment Letter on SEC Financial Literacy Study
02.03.12 Committee Comment Letter on Volcker Rule Proposal
02.02.12 Proposed Rule - Longevity Annuity Contracts
02.02.12 Rev. Rul. 2012-3
02.02.12 Rev. Rul. 2012-4
02.02.12 Fee Disclosures - Final Rule
02.02.12 DOL Fact Sheet - Fee Disclosure
02.02.12 Changes to Final Fee Disclosure Rule
02.02.12 Defined Benefit Plan Distributions
02.02.12 Council of Economic Advisers Report on Retirement
12.15.11 Committee Comment Letter Filed with FIO
12.12.11 Comment Letter Filed with FINRA on Proposed Books and Records Rule
12.06.11 Committee Comment Letter on Proposed FINRA Supplemental FOCUS Report
11.09.11 Committee Comment Letter on IRS Notice 2011-68
10.06.11 Committee Comment Letter on SEC Process for Review of Regulations
09.26.11 Committee Comment Letter on Stable Value Contracts
09.23.11 Committee Comment Letter on proposed SEC definition of "Municipal Advisor"
09.06.11 Committee Comment Letter Regarding Study of Stable Value Contracts and Request for Extension
08.26.11 Committee Comment Letter on SEC proposed amendments on broker-dealer reports
07.22.11 Committee Comment Letter on the definition of "Swap"
07.21.11 Committee Comment Letter on FINRA Supervision Rules
06.01.11 Committee Comment Letter on FINRA's Investment Company Securities Rule Filing
05.13.11 Committee Comment Letter on Third-Party Service Providers
04.11.11 Committee Comment Letter on 81-100 Group Trusts
04.08.11 Committee Comment Letter-- Proposed New Registration Category for Operations Personnel
03.15.11 Committee Comment Letter on FINRA RN 11-04 (Private Placements of Securities Rule)
02.23.11 Committee Comment Letter on SEC Municipal Adviser Proposal
02.03.11 Committee Comment Letter on the Definition of Fiduciary
12.27.10 Committee Comment Letter on FINRA Disclosure Statement Proposal
12.03.10 Committee Comment Letter on the Definition of "Swap"
11.23.10 Comment Letter on FINRA Books and Records Rule Proposals
11.05.10 Committee Comment Letter on SEC's Mutual Fund Distribution Fee and Confirmation Proposals
09.10.10 Committee Comment Letter on FINRA Suitability/Know Your Customer Proposal
08.30.10 Committee Comment Letter on SEC Study on Obligations of Brokers, Dealers, and Investment Advisers
08.30.10 Committee Comment Letter on FINRA Proposal on Reporting Requirements
07.30.10 Committee Comment Letter on Registration and Qualification Requirements for Certain Operations Personnel
05.05.10 Committee Comment Letter on Proposed DOL Investment Advice Rule
05.03.10 Committee Comment Letter on Use of Annuities in DC Plans
03.30.10 Update on FINRA Rulebook Consolidation
03.05.10 Committee Comment Letter - RN 10-01 (Membership Application Proceedings)
03.02.10 Committee Comment Letter - RN 09-70 (Registration and Qualification Requirements)
02.22.10 Committee Comment Letter - RN 09-69 (Payments to Unregistered Persons)
12.30.09 Committee Comment Letter - FINRA Rule 2211 (FINRA Variable Product Advertising Rule Proposal)
11.20.09 Committee Comment Letter - RN 09-55 (Proposed New Rules Governing Communications with the Public)
10.13.09 Committee Comment Letter- Customer Confirmations
09.17.09 Press Release Regarding 2009 Gallup Report
09.17.09 2009 Gallup Report Fact Sheet
09.16.09 2009 Gallup Survey of Owners of Non-Qualified Annuity Contracts
08.20.09 Memorandum on Private Separate Account Reporting Filed with Treasury Department
07.10.09 2009 Update to 2008 E&Y Retirement Vulnerability Report
06.29.09 Comment Letter Filed with FINRA Regarding Proposed Consolidated FINRA Rules Governing Suitability and Know-Your-Customer Obligations
06.11.09 Comment Letter Filed with the SEC Regarding Proposed Rule Change to Adopt FINRA Rule 2231 (Customer Account Statements) in the Consolidated FINRA Rulebook
06.05.09 Comment Letter Filed with FINRA Regarding Proposed Consolidated FINRA Rule Governing Personal Securities Transactions for or by Associated Persons
06.01.09 Comments on Section 403(b) Prototype Plan Program
05.12.09 Comment Letter Filed with the SEC Regarding Proposed Adoption of Rule 2320 in the Consolidated FINRA Rulebook
04.20.09 Comment Letter Filed with the SEC Regarding Proposed IFRS Roadmap
04.17.09 Comment Letter Filed with the SEC Regarding Proposed Changes to Forms U4 and U5
02.20.09 Comment Letter Filed with FINRA Regarding Financial Responsibility and Related Operational Rules
02.20.09 Comment Letter Filed with FINRA Regarding Proposed Consolidated FINRA Rule Governing Information and Data Reporting and Filing Requirements
02.18.09 Comment Letter Filed with the SEC Regarding Proposed Adoption of Financial Responsibility Rules in Consolidated FINRA Rulebook
12.19.08 Comment Letter Filed with the SEC Regarding Effective Date of FINRA Rule Governing Transactions in Deferred Variable Annuities
11.17.08 Supplemental Comment Letter Filed with the SEC Regarding Proposed Rule 151A
11.17.08 Supplemental Comment Letter Filed with the SEC Regarding Proposed Rule 12h-7
11.03.08 Committee of Annuity Insurers/ACLI Letter re Partial Exchanges of Annuity Contracts
09.30.08 Comment Letter Filed with FINRA Regarding Proposed New Rules Governing Communications About Variable Insurance Products
09.10.08 Comment Letter Filed with the SEC Regarding Proposed Rule 151A
09.10.08 Comment Letter Filed with the SEC Regarding Proposed Rule 12h-7
07.23.08 Comment Letter Filed with the SEC Regarding Interactive Data Proposals
07.14.08 Retirement Vulnerability: A New Study by Ernst & Young LLP
07.01.08 Comment Letter Filed with FINRA Regarding Proposed Rule Change Relating to Sales Practice Standards and Supervisory Requirements for Transactions in Deferred Variable Annuities
06.13.08 Comment Letter Filed with FINRA Regarding Regulatory Notice 08-23, Proposed Consolidated FINRA Rules Governing Financial Responsibility
06.13.08 Comment Letter Filed with FINRA Regarding Regulatory Notice 08-24, Proposed Consolidated FINRA Rules Governing Supervision and Supervisory Controls
06.13.08 Comment Letter Filed with FINRA Regarding Regulatory Notice 08-26, Proposed Consolidated FINRA Rules Addressing Investor Education and Protection
05.30.08 Letter to IRS Requesting Items for Inclusion on 2008-2009 IRS/Treasury Guidance Priority List
05.19.08 Comment Letter Filed with IRS and Treasury Department Regarding Rev. Proc. 2008-24 and Partial Exchanges of Non-Qualified Annuity Contracts
03.19.08 White Paper on FINRA Regulation of Sales of Annuities by Securities Firms
02.28.08 Comment Letter Filed with the SEC Regarding Mutual Fund Summary Prospectus Proposal
01.31.08 Comment Letter Filed with IRS Regarding Notice 2007-15 Regarding Procedures for Correcting Section 817(h) Diversification Failures
01.24.08 Comment Letter Filed with the SEC Regarding FINRA Proposed Delay of Implementation of Variable Annuity Transaction Rule
01.14.08 Copy of IRS Notice 2008-18 Regarding Annuity and Life Insurance Contract Reserve Methodologies
11.16.07 Federal Register Copy of Form 5500 Annual Report Guidance
11.16.07 Federal Register Copy of Annual Reporting and Disclosure Guidance
11.15.07 Copy of Final Regulations Defining "Salary Reduction Agreement" for Purposes of IRC Section 3121(a)(5)(D)
11.13.07 Comment Letter on DOL Proposed Regulations Regarding Fiduciary Standards for Selecting Annuity Contracts for Defined Contribution Retirement Plans
10.29.07 Comment Letter on Proposed Regulations under IRC Section 817(h)
07.26.07 Final 403(b) Regulations (Federal Register)
07.19.07 Comment Letter Filed with SEC Regarding Rule 12b-1 Under the Investment Company Act of 1940
06.12.07 Comments on IRS Notice 2007-15 Regarding Procedures for Correcting Inadvertent Failures to Comply with Section 817(h) Diversification Requirements

The Committee of Annuity Insurers

The Committee of Annuity Insurers, based in Washington, D.C., was formed in 1981 to address Federal legislative and regulatory issues relevant to the annuity industry and to participate in the development of federal tax and securities policies regarding annuities. Since its formation, the Committee has played a prominent role in shaping the federal government’s policies with respect to annuities.  The Committee is a coalition of 28 of the largest and most prominent issuers of annuity contracts. The member companies of the Committee represent approximately 80% of the annuity business in the United States.  The Committee is represented in its work by two law firms, Davis & Harman LLP and Sutherland, Asbill & Brennan LLP.

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