Comments on FINRA Rulemaking

Notice of Filing of Proposed Rule Change Relating to Sales Practice Standards and Supervisory Requirements for Transactions in Deferred Variable Annuities

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Date Received
Date Letter Type Commenter Name
Public Comment Sutherland Asbill & Brennan LLP, on behalf of the Committee of Annuity Insurers
Public Comment Jim S. Wrona, FINRA, Washington, District of Columbia
Public Comment Carl B. Wilkerson, Vice President & Chief Counsel, American Council of Life Insurers
Public Comment Neal E. Nakagiri, President, CEO, CCO, NPB Financial Group, LLC, Burbank, California
Public Comment Cheryl Tobin, Asst. Vice President Counsel, Pacific Life Insurance Company, Newport Beach, California
Public Comment Clifford Kirsch, Sutherland Asbill & Brennan LLP, on behalf of the Committee of Annuity Insurers
Public Comment Dale E. Brown, President and CEO, Financial Services Institute
Public Comment Heather Traeger, Assistant Counsel, Investment Company Institute
Public Comment Michael P. DeGeorge, General Counsel, NAVA, Inc.
Public Comment William A. Jacobson, Associate Clinical Professor, Cornell Law School, and Director, Cornell Securities Law Clinic, Ithaca, New York
Public Comment Heidi Stam, Managing Director and General Counsel, Vanguard
Public Comment Teresa Luiz, Greenwood Village, Colorado
Public Comment Theodore Tsung, Financial Services Software Innovator - Founder of digiTRADE and EAssist, New York, New York
Public Comment Laurence S. Schultz, President, Public Investors Arbitration Bar Association
Public Comment Darrell Braman, Vice President and Associate Legal Counsel and Sarah McCafferty, Vice President and Chief Compliance Officer, T. Rowe Price Investment Services, Inc.
Public Comment Deborah Peters, Director, Broker Dealer Compliance, EquiTrust Marketing Services, LLC

Last Reviewed or Updated: Dec. 18, 2025

File Number
SR-FINRA-2008-019
Release Number
34-57920
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