Conflicts of Interest – Fixed Indexed Annuities – Best Practices


This compliance checklist is intended to assist an investment adviser identify and mitigate some of the conflicts of interest associated with the investment adviser firm’s supervised persons who also serve as an insurance agent and sell fixed indexed annuities (“FIAs”) for commissions to investment adviser clients.


To the extent that an investment adviser firm permits its affiliates and/or supervised persons to offer for sale fixed indexed annuities (“FIAs”) and receive commissions for such sales to individual who are also investment advisory clients, the SEC and state securities regulator have taken the position that these types of arrangements generally create various conflicts of interest for the investment adviser firm depending upon the circumstances. This checklist identifies and describes some common and less common conflicts of interest facing an investment adviser firm which permits its investment adviser representatives to sell FIAs to its investment advisory clients.  The checklist review certain best practices for disclosing and mitigating the conflict of interest associated with the sale of fixed indexed annuities.

The sample checklist discusses how an investment adviser firm should draft generally a conflict of interest disclosure associated with a supervised person acting as an insurance agent who sell FIAs to investment advisory clients for commissions; however, this checklist does not provide sample disclosure for the Form ADV Part 2A.

This sample document  is delivered via the purchasers online subscription account with RIA Compliance Consultants.

Included with Bronze, Silver, Gold and Platinum Packages.  Last updated August 2021.

Products Related to Investment Adviser Fixed Indexed Annuities Conflicts of Interest Best Practices Checklist


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This sample document should be considered a starting point, and purchaser should not treat this sample document as a final document ready for use.  The sample document has not been customized to the purchaser’s business model, the specific investment advisory rules applicable to the purchaser’s investment adviser or the written supervisory procedures and code of ethics of purchaser’s investment adviser.

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Since this sample document may not reflect the specific investment advisory requirements of the purchaser’s securities regulator, the purchaser should check with the securities regulator(s) with jurisdiction over its investment adviser or review any applicable rules before using this document.

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