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