Home      Login

Abstract: 

Registered index-linked annuities represent the fastest-growing category of SEC-regulated insurance contracts in the annuity marketplace. This article explores the evolving SEC RILA regulatory landscape. It begins with an explanation of these innovative securities, including their general design, feature functionalities, and risk/return profiles. This article then provides an overview of the new SEC RILA registration and disclosure framework, which was adopted in July 2024 at the direction of Congress. As part of this discussion, the authors compare this new tailored framework to the ill-fitted prior regulatory regime. The article concludes by proffering further SEC regulatory reforms that may be on the horizon for RILAs, as well as certain other types of registered insurance contracts.

Keywords: Registered Index-Linked Annuities (“RILAs”); Index-Linked Variable Annuities (“ILVAs”); Bounded Return Structure; ILVA Lifecycle; Special Feature Functionality; SEC Regulation of RILAs; Form N-4

Affiliations:  1: Eversheds Sutherland (US) LLP; 2: Eversheds Sutherland (US) LLP.