The purpose of this paper is to summarize and discuss FINRA Rule 2821, which covers broker‐dealer sales practices with respect to purchases and exchanges of deferred variable annuities.
The paper describes the transactions to which the rule applies; summarizes the four primary components, which relate to suitability obligations, review and approval, supervisory procedures, and training programs; discusses the background and history of the rule; and explains a conditional exemption from Rules 15c3‐3 and 15c3‐1 that permit a principal's review of transactions subject to Rule 2821 for up to seven days without triggering requirements for additional capital or customer reserve accounts.
The paper finds that deferred variable annuities now join a very small group of securities products that have their own custom suitability requirements.
The paper provides practical guidance by experienced lawyers specializing in financial services.
Puretz, J.S., Zacharski, A.H., Rosenblat, A. and Ryan, A.C. (2008), "SEC approves FINRA rule governing sales practices of deferred variable annuities", Journal of Investment Compliance, Vol. 9 No. 2, pp. 60-64. https://doi.org/10.1108/15285810810886216
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