As states adopt the new NAIC Model Regulation 275, a new annuity standard of care rule becomes effective. This new “best interest” standard, which replaces the old suitability standard, impacts the sales process requiring producers to use new point-of-sale form requirements, producer disclosures, and documentation obligations.

New Required NAIC Training (LIMRA/RegEd)

All producers will be required to complete a new training course related to compliance with the new model. Depending on whether the producer has already completed the 4-credit annuity training course in the past, he or she must also complete either (1) a new 1-credit hour training course or (2) a newly revised 4-credit course which incorporates the new model. Training courses are available through external training platforms such as RegEd or LIMRA. Per the rule, we will NIGO business if the training is not completed within the states required timeline in each state where the new model has been adopted.

Below is a state-by-state grid that outlines the date these changes take effective.

States with an adopted new annuity standard of care rule requirement	Effective date of rule*	Training required by date
Alabama	1/1/2022	7/1/2022
Arizona	12/31/2020	7/1/2021
Arkansas	7/8/2021	1/1/2022
Connecticut	3/1/2022	9/1/2022
Delaware	8/1/2021	2/1/2022
Idaho	7/1/2021	1/1/2022
Iowa	12/31/2020	7/1/2021
Maine	1/1/2022	7/1/2022
Michigan	6/29/2021	12/29/2021
Montana	10/1/2021	4/1/2022
Nebraska	1/1/2022	1/1/2022
North Dakota	1/1/2022	7/1/2022
Ohio	8/14/2021	8/14/2021
Rhode Island	4/1/2021	10/1/2021
Texas	9/1/2021	1/1/2022
Virginia	9/1/2021	3/1/2022

* New forms required on effective date: Producer Disclosure Form (32931) and Best Interest Attestation Form (32921Z)

NAIC Model Regulation 275 State-By-State Adoption