New Era for Variable Product Fund Substitutions: SEC Removes Obstacles
By EsqSocial Corporation 10/05/21
About 20 years ago, the SEC began scrutinizing variable product fund “substitution” applications in ways that increased both the time required to obtain SEC approval and the conditions necessary to obtain such approval. The Investment Company Act of 1940 (“1940 Act”) generally prohibits an insurance company from substituting one fund supporting its SEC-registered variable products (an “underlying fund”) for another, unless and until the SEC approves the substitution....
By: Carlton Fields