New Registration Framework for RILA Contracts

This white paper discusses the new registration framework adopted by the Securities and Exchange Commission (SEC) for registered index-linked annuity (RILA) contracts, effective July 1, 2024. The framework allows RILA issuers to use Form N-4, previously reserved for variable annuities, thus streamlining the registration process. The amendments to Form N-4 focus on enhancing disclosure related to RILAs and market value adjustment annuities (MVAs), addressing investor concerns about the complexity of these products. The paper outlines significant changes, including new risk disclosure requirements and the ability to satisfy prospectus delivery obligations through summary prospectuses. It also details the new rules for payment of registration fees, allowing RILA and MVA issuers to pay fees in arrears and net redemptions against new sales. The overall goal of these changes is to simplify the registration process and improve investor understanding of RILA products, while also reflecting the SEC's collaborative efforts with industry stakeholders over the past decade.