Variable Insurance Product Disclosure Reform: A Future-Proof Proposal?
August 01, 2019
The proposal would apply to variable insurance products on Forms N-3, N-4, and N-6.
The product disclosure reform is intended to permit the use of an initial summary prospectus for variable insurance products currently offered to new investors, the use of an updating summary prospectus for existing investors, and online delivery of underlying fund prospectuses and other documents; update the disclosures required by registration forms for variable insurance products; require variable insurance product registrants to submit interactive data files about their products; and make certain technical and conforming changes to the regulatory framework.
The attorneys report that almost all public comment on the proposal was complimentary of the SEC’s intentions, but came down strongly on either side of the body’s implementation, with life insurance and mutual fund industry groups enthusiastically embracing the proposal, and consumer groups condemning it.
