Of the states that have passed NAIC model regulation, this list leaves out California, Hawaii, Nebraska, New York, South Dakota, and Utah. Texas is the first state to decide which states have an annuity suitability training requirement that is substantially similar to their own. There might be some explanation for excluding those states:

  • Utah does not have CE requirement as part of their Suitability rule
  • California is just very different from the Model
  • New York is still applying an Emergency rule and has not formally adopted the Model
  • South Dakota’s law is somewhat less robust than the Model reg.
  • Hawaii, until very recently, did not recognize reciprocity (it now does)

It is unclear why Nebraska was omitted as the Model was adopted there as written.

Lead by NAFA’s legal Counsel Pam Heinrich, we have been actively engaged in mobilizing resources to clarify the situation with the Texas DOI.