January 4, 2008
2821. Members Responsibilities Regarding Deferred Variable Annuities
(c) Principal Review and Approval
As a $50,000 Net Capital B/D (introducing broker-dealer) we are not permitted to hold checks overnight. A 7-day review period will require that we not accept a premium payment until after Principal review. Obviously, this puts our firm on a competitive disadvantage with larger firms who can hold checks. This will also confuse clients when we can accept payment for stocks, bonds and mutual funds at the time of application but wait over 1-week before accepting a VA Principal Payment.