DOL - Department of Labor - PTE 2020-02

  • 2024 - Letter - NAIFA to GOV-DOL/EBSA - RE: Comments of NAIFA to RIN 1210–AC02: Retirement Security Rule: Definition of an Investment Advice Fiduciary and ZRINs 1210-ZA32, 1210-ZA33, 1210-ZA34 
    • (p13) - VI. The Proposed Rule Excludes Independent Marketing Organizations from PTE 2020-02.
      • Independent marketing organizations (“IMOs”) are entities designed to work with independent insurance agents and insurers to deliver non-securities-based insurance products, such as life insurance and fixed annuities, to customers.
      • IMOs develop relationships with small agencies and work with independent agents to provide them access to insurance products from various carriers.
    • The Proposed Rule declined to name IMOs as a “Financial Institution” under the proposed amendments to PTE 2020-02.44
      • This restrictive definition of “Financial Institution” would limit IMOs dealing in annuities and, by extension, the independent insurance agents with whom they work from utilizing PTE 2020-02.