Regional VP-South

Effective August 14, 2021 annuity sales in Ohio will require compliance with the new disclosure, documentation and training requirements based on changes to the NAIC’s Suitablity In Annuity Transaction Model Regulation. This took effect in Michigan on June 29, 2021.

Under the new regulatory requirements, you are required to act in the best interest of the client whenever making a recommendation of an annuity – under circumstances known at the time of recommendation, without placing your or the insurer’s financial interest ahead of the client’s interest. You have acted in the best interest of the consumer if you satisfy the obligations of care, disclosure, conflict of interest, and documentation as specified in the regulation.

What This Means for You

If you do business in Ohio or Michigan you are subject to new training requirements, duties and responsibilities which you must review and understand to satisfy the law and meet carrier requirements.

New Training & CE Requirements

Agents who satisfied their 4-hour annuity training course prior to June 29,2021 must complete one of the following:

  • A new 4-hour annuity training course approved by the state insurance department; or
  • An additional one-time 1 hour credit training course approved by the state covering sales practices under the new NAIC regulation

You may satisfy the CE requirement through approved vendors such as: SuccessCE, WebCE, ect.


  • Ohio – August 14th, 2021: Michigan – December 29, 2021 *However many carriers are requiring the training to be completed now and new forms to be used now.

After these dates if you have not competed the required training applications will be rejected.

New Forms Required

  • Best Interest Supplement & Disclosure forms to establish that the client considered important information and that you, the agent, complied with specific requirements under the new regulation.

Compensation Disclosure

Under the new regulation, clients have the right to request additional information about your cash compensation for the annuity sale. Some carriers include a section covering compensation on their Best Interest Form while others have an additional form. Be sure to know what is required by the carrier you are working with.

Contact Wholehan Marketing with questions and to see how our software programs help you comply 1-800-535-6080