November 28, 2019
The SEC is not the primary regulator of these products, the state are. They control product design, solvency, c
contract disclosure, and the like.
The SEC should let the contract stand as a prospectus and only provide the list of investment options each year.
The state approach is better. It only provides you disclosure of the feature you own. The fees are specific to you. It is a better more straight forward approach that does not require an annual restatement of a ton of information.
The SEC can regulate the funds, sales practices and impose the antifraud provisions. The rest is covered by the states... you can even call the contract a prospectus or registration statement if that helps you sleep at night.
If you are not adding value, please step away.