On September 24, 2015, NAFA filed its second official comment letter with the Department of Labor-Employee Benefits Security Administration in regard to the Department’s Proposed Conflict of Interest Rule (RIN 1210-AB32), the Proposed Best Interest Contract Exemption (ZRIN 1210-ZA25), and the Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption 84-24 (ZRIN 1210-ZA25).

Response excerpt:

On behalf of NAFA, the National Association for Fixed Annuities, I am pleased to have the opportunity to submit these additional comments on the Department of Labor’s proposed new definition of a fiduciary and the proposed amendments to Prohibited Transaction Exemption (PTE) 84-24 (collectively, “the proposed rule”).
As we made clear in our prior letter, NAFA commends the Department for recognizing that PTE 84-24 is the appropriate regulatory exemption for non-security annuities – i.e., fixed annuities – under the proposed rule. We believe that this is the appropriate exemption because only fixed annuities – unlike all other types and categories of retirement investment vehicles – offer two insurance-backed, contractual guarantees: guaranteed protection of principal and a guaranteed annuitized income payout.

Continue Reading the Comment Letter HERE.