RILA Modernization

On July 1, 2024, the Securities and Exchange Commission (“SEC”) adopted rule and form amendments that require issuers of registered index-linked annuities (“RILAs”) to exclusively register their offerings on Form N-4.  The final amendments (“RILA Amendments”) are focused on increasing and simplifying disclosure to RILA investors.  Under the RILA Amendments, Forms S-1 and S-3 under the Securities Act of 1933 (“Securities Act”) and Rule 424 under the Securities Act are no longer available for RILA offerings. 

The RILA Amendments mostly adopt, unchanged, the modifications discussed in the original proposal (the “RILA Proposal”).  The RILA Amendments will become effective 60 days after date of their publication in the Federal Register.