Tim O'Connor's Blog

FINRA Offers Guidance on FINRA Suitability Rule 2111

In Regulatory Notice 12-55, FINRA addressed a requirement of FINRA Rule 2111 (Suitability), that a broker-dealer or Registered Representative “have a reasonable basis to believe that a recommended transaction, or  involving a security or investment strategy involving a security or securities, is suitable for the customer” based upon the customer investment profile.  Since the implementation […]

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Deferred Variable Annuities and Client Suitability

Deferred variable annuities are investment products which have features with both insurance and securities (mutual fund) characteristics.  They may be purchased in non-qualified (non-retirement) type accounts as well as in tax-qualified, employer-sponsored retirement or benefit plans.    FINRA Conduct Rule 2330 requires that brokers selling these products adhere to FINRA’s new Suitability Rule 2111 and […]

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Capital Region and Upstate New York Banks Are Selling Variable Annuity Contracts to Senior Citizens – Securities/Investment Law Update

Over the past several years, a number of banking institutions have been involved with the sale of variable annuities to retirees and senior citizens.  These sales take place through their FINRA-registered broker-dealer affiliates, such as Uvest (First Niagara Bank), Key Investments (KeyBank), COO (Citizens Bank), and M&T Securities (M&T Bank).    Through branch offices in […]

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Living Benefit Annuities – Securities and Investment Law

In an article entitled Buying Your Own Pension, in the July/August 2012 edition of the AARP Bulletin, veteran financial writer, Jane Bryant Quinn, examines the wisdom of living benefit variable annuities.   In the article, those considering the purchase of variable annuities with living benefits are advised to first look at the annual expenses and […]

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