Joint SEC No-Action Letter Regarding Insurance Networking Arrangements

SIFMA, the American Council of Life Insurers and the Committee of Annuity Insurers submitted a joint no-action letter to the SEC under Section 15(a) of the Securities Exchange Act of 1934 ("Exchange Act") in regard to insurance agencies' networking arrangements. The letter requires that the insurance agencies: (1) enter into arrangements with registered broker-dealers ("insurance networking arrangements") for the offer and sale of variable annuity contracts, variable life insurance policies, and other life insurance policies or annuity contracts that are also securities or are otherwise registered as securities ("variable products"); and (2) make certain transaction-based payments, without the insurance agencies registering as broker-dealers under Section 15(b) of the Exchange Act.The SEC staff stated that the conditions set forth in the letter are generally similar to those in prior networking letters involving insurance agencies, except that the SEC liberalized one of the conditions relating to the corporate separation of the insurance agency and the broker-dealer.

View letter in full here (links externally to SEC website).
For a general discussion of networking arrangements, see Lofchie's Guide to Broker-Dealer Registration - Registration Requirement.