August 17, 2020
Is rule 30e-3 being rescinded with respect to insurance product funds? The delivery obligation is that of the separate account (a UIT) and not the N-1A issuer.
I think it should be. There is no reason not to provide this same information to Annuity investors. In fact it may be more important since annuity investors may not receive a fund prospectus.
I think there is no need to deliver a semiannual report so long as performance, holdings and financials are available online.
I agree with a prior commenter that variable product Underlying fund appendix should disclose gross expenses as will be required under your marketing rules.
I also think we should default investors with an email address on file to get electronic delivery (with the ability to opt out). If we cant trust the USPS for mail-in ballots, how can we trust it to provide documents about our life savings.
Finally, I am opposed to the AFFE change. The disclosure worked, why make it more difficult for investors to understand.