Indexed Annuity and Insurance Products Task Force

Welcome to the home page of the Indexed Annuity and Insurance Products Task Force. The Indexed Annuity and Insurance Products Task Force's mission is to monitor and report on the status of indexed life and annuity products in the aftermath of 151A and in light of the Harkin Amendment to the Dodd-Frank Wall Street Reform and Consumer Protection Act.

If you have a question or comment, please contact Gary Cohen or Kristin Shepard.

What's New

• SEC, State and FINRA Regulation Of Indexed Insurance Products Under Dodd-Frank Act , PLI Investment Management Institute, February 10-11, 2011.
  

• Harkin Amendment and the Abrogation of Rule 151A: A Suitable End to Securities Regulation of Indexed Products?, PLI Seminar on Regulatory Reform of Insurance Products in 2011, January 28, 2011.

• Current SEC, FINRA, Insurance, Tax, and ERISA Regulatory and Compliance Issues, Including the Impact of the Dodd-Frank Reform Act, ALI-ABA Conference on Life Insurance Company Products, October 28-29, 2010.
  

• SEC Withdraws Rule 151A

• Rule 151A Vacated

• Amended Judgment Vacating 151A

• Order Accompanying Judgment Vacating 151A

• Reissued 151A Opinion

• SEC Breaks Six-Month Silence on Rule 151A

• SEC Status Report

• Amendment to HR 4173 (Harkin Amendment)

Articles

• Future SEC Regulation of Indexed and Other Products in Question, Expect Focus, Vol. IV, Fall 2010
  

• Rule 151A Crushed by Courts, Congress, Expect Focus, Vol. III, Summer 2010

• The End for Embattled Rule 151A?, Expect Focus, Vol. II, Spring 2010
  

• SEC Fights to Save Rule 151A, Expect Focus, Vol. I Winter 2010

• Litigation to Overturn SEC Index Annuity Rule, The Investment Lawyer, Vol. 16, No. 7, July 2009

• Spotlight on 151A, Expect Focus Vol. I Winter 2009

• More Uncertain Times for Indexed Annuities, Expect Focus, Vol. I Winter 2009

• Parsing the 151A Labryinth, Expect Focus, Vol. IV Fall 2008

• Proposed Rule 151A Sweeping Changes, Expect Focus, Vol. III Summer 2008

Client Alerts

• SEC Withdraws Rule 151A, October 19, 2010

• Rule 151A Vacated, July 13, 2010

• SEC Breaks Six-Month Silence on Rule 151A, June 23, 2010

• SEC Decides To Proceed with Rule 151A Analysis, But Subject to a Two-Year Stay, December 9, 2009

• Additional Briefing in Rule 151A Litigation, December 2, 2009

• SEC Responds to Old Mutual Petition for Two-Year Stay of Rule 151A, September 29, 2009

• Mixed Results in Rule 151A Opinion, July 22, 2009

• SEC Invites Company Input on Index Annuity Rule 151A, May 29, 2009

• Rule 151A Litigation Oral Argument, May 11, 2009

• SEC Adopts New Registration Rule for Index Annuities, December 17, 2008
  

151A Litigation

• Ameican Equity Opening Brief
• NAIC & NCOIL Petition for Consolidation with American Equity Petition Document
• NAIC & NCOIL Petition for Review of 151A
• NAIC Opening Brief Phillip Roy Financial Services and Phillip Wasserman Amicus Brief
• Allianz Life Insurance Company Petition as Amicus Curiae
• Allianz Life Insurance Company Brief SEC's Brief
• Oral Argument in Suit Against SEC
• Clerk's Order
• Judgment
• Opinion
• American Equity Order
• Petition for Panel Rehearing
• SEC Response to Petition for Panel Rehearing
• U.S. Court of Appeals Order for Additional Briefs
• OM Financial Life Insurance Company's Supplemental Brief
• OM Financial Life Insurance Company's Second Supplemental Brief
• American Equity Supplemental Brief
• American Equity's Second Supplemental Brief
• Unopposed Motion for Leave
• SEC Supplemental Brief
• American Equity Second Supplemental Brief on Petition for Review of Final Rule
• OM Financial Life Insurance Company's Second Supplemental Brief in Support of its Petition for Panel Rehearing
• SEC Status Report
• Amended Judgment Vacating 151A
• Order Accompanying Judgment Vacating 151A
• Reissued 151A Opinion

SEC Releases and Comments

• Text of SEC's Adopting Release
• Text of Commissioner Parades' Dissent

Anti-151A Legislation

• H.R. 2733 Fixed Indexed Annuities and Insurance Products Classification Act of 2009 (Meeks-Price Bill)
  
• Amendment to H.R. 4173 - Amendment to the Restoring Financial Stability Act financial reform bill that would enhance the protection of seniors and other consumers (Harkin Amendment)

Our Team

Resources

• Agents Sales Journal
  
• Stop SEC 151A
  
• NAFA No 151A