June 30, 2008
EAssist would like to offer comment on the rule filing by the Financial Industry Regulatory Authority, Inc. (FINRA), which seeks to amend certain rule changes relating to sales practice and supervisory requirements for transactions in deferred variable annuities.
In the proposed rule amendment to Rule 2821(c), you have proposed that Principal review and approval is to occur no later than seven business days after an office of supervisory jurisdiction of the member receives a complete and correct application package
While we applaud the amendment to the earlier requirement that reviews be completed within seven days of the customer signing the application, we feel that the new complete and correct language inserts a level of ambiguity that can only be addressed by technology automation.
Affordable technologies are available to this industry that pre-populate and validate new application forms, and automate the process between OSJ and rep. These technologies facilitate the quick completion of new applications and significantly reduce, if not eliminate, Not In Good Order (NIGO) submissions.
By endorsing the use of technologies that meet FINRA criteria, the inevitable back-and-forth leading up to the confirmation of a complete and correct application can be conducted in a fraction of the current allocated time, and is also transparent to the compliance team for real-time process review.
We appreciate the opportunity to comment on the proposal. If you have any questions about our comments or need additional information, please do not hesitate to contact us.