The SEC has recently adopted tailored disclosure requirements and offering processes for registered index-linked annuities (RILAs) and registered market value adjustment annuities (registered MVA annuities, and collectively with RILAs, nonvariable annuities). These new requirements include structured data disclosure mandates for Form N-4.
The amendments are designed to provide decision-useful guidance to investors regarding non-variable annuities and will:
- require offerings of RILAs and registered MVA annuities to be registered on Form N-4
- provide investors with tailored disclosures and key information about complex products
- update and improve the registration, filing, and disclosure structure for non-variable annuities
- update the form for all offerings, including those of variable annuities, and make technical amendments to other insurance product registration forms
- implement the requirements related to RILAs contained in Division AA, Title 1 of the Consolidated Appropriations Act, 2023, and incorporate the results of investor testing conducted by the SEC
- require many of the newly added disclosures on Form N-4 to be tagged in Inline XBRL, a structured, machine-readable data language
Under the new amendments, RILA and registered MVA annuity advertisements and sales literature are subject to an existing SEC rule that provides guidance related to sales literature that may be materially misleading according to the Federal securities laws. The SEC also voted to approve technical amendments to Forms N-6 and N-3 to correct errors from previous SEC rulemakings.
For further details on the amendments, please see the Registration for Index-Linked Annuities and Registered Market Value Adjustment Annuities; Amendments to Form N-4 for Index-Linked Annuities, Registered Market Value Adjustment Annuities, and Variable Annuities; Other Technical Amendments final rule on the SEC’s website.
The amendments go into effect 60 days following publication in the Federal Register. Filers must adhere to most of the final amendments to Form N-4 and the related rule and form amendments by May 1, 2026. Insurance companies are required to comply with the amendments to Rule 156 on the effective date.
Sources:
SEC Adopts Tailored Registration Form for Offerings of Registered Index-Linked and Registered Market-Value Adjustment Annuities (sec.gov)
Fact Sheet: Registration for Index-Linked Annuities and Registered Market Value Adjustment Annuities and Amendments to Form N-4 (sec.gov)