Fair Consumer Outcomes

  • GFIA – Global Federation of Insurance Associations: In addition, GFIA is concerned that the meaning of “fair treatment of consumers” may be considered different from, or in addition to, legally prescribed standards.
    • Companies may exceed those standards voluntarily, but supervisors should define “fair treatment” solely in terms of the legally established standards of insurer conduct toward consumers.
    • GFIA would also suggest that the word “fair” or “unfair” be replaced with “appropriate” or “inappropriate” throughout the paper.
  • IAIS: The terms “fair” and “unfair” are well established and understood in the ICPs. The paper must be read with this understanding in mind.  (p4)

2021 0823 – IAIS – Resolution of public consultation comments on draft Issues Paper on Insurer Culture, 23 June – 23 August 2021 – 46p

2021 – IAIS – Public Consultation on draft Issues Paper on Insurer Culture  —  [BonkNote]

  • GUIDANCE CONDUCT OF INSURANCE BUSINESS AND FAIR TREATMENT OF CUSTOMERS, ccir-ccrra – 23p
  • IAIS – ICP 19 Conduct of Business
    • The supervisor requires that insurers and intermediaries, in their conduct of insurance business, treat customers fairly, both before a contract is entered into and through to the point at which all obligations under a contract have been satisfied. – [link]

Q: Are Life Insurance Policies Being Sold For a Death Benefit or an Investment Vehicle?

  • Current
    • Be Your Own Bank
    • LIRP – Life Insurance Retirement Plan
    • Curtis Ray
    • Dout Andrew
    • Tom Hegna
    • etc
  •  MetLife
    • 1990s – Nurses 50 /50
    •  FSOC
  • I didn’t buy a Life Insurance Policy – Horton
  • College Funding
  • Looks like an Annuity
    • SOA
    • 1994 0213 – The Washington Post – Beware of Life Insurance Firms Selling Policies as Annuities, By Jane Bryant Quinn – [link]
  • 2010’s – Walker vs. LSW – 
  • 2025 – LC – Kyle Busch vs. Pacific Life Insurance Company  —  [BonkNote]
  • (p232) – Q:  And why did you decide at that time that you were ready to apply for the policy?
  • A: Because I was satisfied that this would meet my retirement needs, receiving $93,000 a year for tax-free retirement, turning that money that I had targeted for my nest egg into this $93,000-a-year income.
    • It sounded like a good product for me.

2014 0416 – DOC 809 – Trial Transcript – Walker v LSW – 236p

  • While we recognize that there are meaningful differences within life insurance products and within annuity products, we also observe as a general matter that policies that provide coverage against death are likely to be viewed by the policyholder as serving primarily a protection purpose rather than primarily a savings purposes. 

— 239. Northwestern Mutual 

2021 06 – IAIS – Liquidity Metrics Phase 1 – Resolution of Comments_(PUBLIC) – 106p

  • Ed FEIGHAN (D-OH):  Well, if insurance is viewed as an investment by the majority of Americans, that’s the result of its portrayal over several decades by the industry.
  • Robert HUNSTAD (ACLI):  I can’t respond to that.  (p301)

1984 0411, 0503, 0510, 0628, 0913 – GOV (House) – Competition in the Insurance Industry – [PDF-759p-GooglePlay]

⇒  Robert Hunstand, senior vice president and actuary, Minnesota Mutual Life Insurance Co., on behalf of the American Council of Life Insurance, ACLI

2009 1231 – Examination Report of AGC Life Insurance Company – Missouri

  • 2009 1231 – Missouri – Examination Report of AIG – AGC Life Insurance Company  —  [BonkNote]  —  25p
    • Filed 2011 0520
    • The current full scope financial examination covers the period from January l, 2007, through December 31, 2009
    • John Huff, Commissioner
  • (p2/6) – AGC Life Insurance Company operates as a holding company that directly owns six domestic life insurance subsidiaries and one foreign subsidiary.
    • The domestic subsidiaries lost $17.5 billion in 2008 as a result of their participation in a securities lending program sponsored by its upstream parent, American International Group, lnc. (”AIG”).
    • AIG made capital contributions in 2008 to substantially offset these securities lending losses from funds primarily obtained from the U.S. government.
    • However the subsidiaries incurred significant damage to their reputations because of their association with AIG and this reputational damage resulted in a substantial loss of business that may be considered a threat to their future level of profitability.
      • ⇒  As a result the subsidiaries could be dependent on additional capital contributions from AlG to maintain their capital positions.
      • ⇒  Because of the damage to its financial condition that developed out of the 2008 financial crisis and the uncertainty of continued support from the U.S. government, it is not certain that AIG will be able to make future contributions to AGC’s subsidiaries if needed.
  • ⇒  AlG’s management performed an assessment in 2009 of its ability to continue as a going concern and concluded that it will be able to finance and operate its businesses for the next twelve months.
    • However it also concluded that it is possible that actual outcomes could be materially different, which could result in substantial doubt about its ability to continue to operate as a going concern.
    • lf AIG is unable to continue to operate as a going concern, management believes this could have a material effect on AGC and its operations.
  • (p1/5) – AGC Life Insurance Company hereinafter referred to as such or as “AGC” or as the “Company.”
    • The Company’s administrative home office is located at 2727-A Allen Parkvay. Houston, Texas 77019, telephone number (713) 522-1111.
    • This examination began on May 17, 2010 and concluded on August 5, 2010.
    • The current full scope financial examination covers the period from January 1, 2007, through December 31, 2009.
  • AIG Inc
  • AIG Life Holdings (US) Inc (Parent)
    • The company’s immediate parent’s name was changed in 2007 from American General Corporation to AIG Life Holdings (US), Inc. 
    • AGC Life Insurance Company operates as a holding company
      • AIG [Inc] made capital contributions [$18.3 Billion] in 2008 to substantially offset these securities lending losses from funds primarily obtained from the U.S. government.
      • …directly owns six domestic life insurance subsidiaries and one foreign subsidiary.
      • …affiliate American General Life Insurance Company (“AGL”) – domiciliary of Texas
      • …AGC Life Insurance Company was incorporated as a life insurance company on September 1, 1982, under the laws of the state of Missouri.
      • AGC is the parent company for most of AIG/AIG Life Holdings’ life insurance subsidiaries.
        • As of December 31. 2009, AGC owned 100% of the common stock of seven life insurance companies.
        • These subsidiaries, in turn, collectively owned 100% of three other insurance companies.
  • 2009 1231 AIG Examination Missouri 1o2

2009 AIG Examination Missouri 2o2

  • (p5/9) – Three additional agreements were executed in 2009 between AIG and the New York Fed and/or the U.S. Department of Treasury that “increased the federal rescue package to over $180 billion and whjch required AIG to issue equity interests in some of its subsidiaries for a reduction in the outstanding balance and maximum amount available to be borrowed under the Fed Facility.
    • AGC was not one of the subsidiaries for which equity interests were issued.
    • Certain of the Fed Facility obligations are guaranteed by certain AIG subsidiaries and are secured by a pledge of certain assets of AIG and its subsidiaries; however AGC is not a guarantor and has not pledged any of its assets to secure those obligations.
2009 1231 – Examination Report of AIG – AGC Life Insurance Company – Missouri (p6/10)
  • (p10/14) – Investment Advisory Agreement
    • Effective January 1, 2002, the Company agreed to the transfer by American General Investment Management, L.P. to AIG Global Investment Corp. of all its rights and all its obligations under the Advisory Agreement effective June 1, 1998.
    • The advisory fees under the agreement are equal to .01 percent of the market value of assets managed. The Company incurred fees of $36,872, $17,807 and $27.544 in 2009, 2008 and 2007, respectively.
    • As part of the sale of AIG’s third party asset management business, the Advisory Agreement was assigned to AIG Asset Management (U.S.), LLC.

Q: Did Insurance Regulators tell AIG to Wind-Down their Securities Lending Business?

  • This regulator said it began discussions with the company about securities lending in 2006.
    • ⇒  AIG told us it was unaware of the regulator’s concerns.  (p15)

2011 09 – GAO – Review of Federal Reserve System Financial Assistance to American International Group, Inc – 152p

  • Eric Dinallo, Dixie Noonan, Richard Scott, Gtreenburg, Mark Hutchings, Martin Sullivan, GAO Report
  • (p60) – Response to Written Questions of the Senate Banking Committee from Eric Dinallo
  • (p65) – 1 According to an unofficial transcript, in my oral statement to the Committee on March 5, which I did not read, but presented from brief notes, I stated that we began working with the company to reduce the securities lending program ”starting in the beginning of 2007.”
    • Later in my testimony, I stated more precisely that ”starting in 2007, we did begin to wind down” the program.
    • While we were working with AIG on issues related to the securities lending program in early 2007, in fact, as noted, we began working with the company specifically on reducing the size of the program towards the end of 2007. 

2009 0305 – GOV (Senate) – American International Group: Examining What Went Wrong, Government Intervention, And Implications for Future Regulation,  Government Intervention and Regulation of AIG CSPAN – [PDF-72p,  VIDEO-CSPAN,  VIDEO-Senate-Error]

  • Securities Lending:
    • As of September 28, 2007, the on-loan balance totaled $91.6 billion, up from $72.5 billion as of August 31, 2006.
    • About $3.1 billion of balances represent trades with AIG companies, mostly with AIG-FP.  (p4)

2007 1023 – AIG Credit Risk Committee (CRC) – 6p

3. Report of the October 2, 2007 CRC Portfolio Review of AIG Global Securities Lending – p4

  • 2008 1009 – WSJ – Further Loan To AIG Shows Fed Miscalculated Risks, By Liam Pleven, Carrick Mollenkamp and Craig Karmin – [link] – <WishList?>
    • AIG’s securities-lender clients flooded the program for their collateral, creating a “mini-run” on the bank, says Doug Slape, chief financial analyst of the Texas Department of Insurance.
    • The company began drawing down on the Fed loan commitment to cover the collateral requests, it told Mr. Slape in recent conversations, he said.
    • By Oct. 3, Moody’s Investors Service said AIG’s default-insurance and securities-lending program had experienced “substantial losses and write-downs” due to mortgage securities.
    • The Texas regulator grew concerned about the exposure in 2007.
      • ⇒  At the time, AIG told Texas it recognized that it needed to retain more cash, Mr. Slape said.
  • 2009 0305 – GOV (House) – Perspectives on Systemic Risk – [PDF-254p
    • Terri Vaughan (NAIC CEO / IA): The New York Superintendent had been working to address the issue of securities lending in AIG, and the insurance company had reduced the amount, and was in the process of reducing it further, when it was overtaken by the problems with the credit default swap operation.
  • 2010 0617 – FCIC – Transcript of Interview with Martin Sullivan_1.pdf – 139p
    • (p127-128) – SEEFER: Do you recall whether or not any of AIG’s insurance regulators directed the company to reduce the balance of those portfolios? I should have–that portfolio?
    • MURPHY: The securities portfolio.
    • SEEFER: The securities lending portfolio.
    • SULLIVAN: I don’t have a recollection of being instructed.
      • I have a vague recollection of one regulator raising questions, but not to the point where instructions were issued, as you articulated.
        • Again from the best of my memory.
    • SEEFER: Which insurance department was that?
    • SULLIVAN: Well, you’re stretching back.
      • To the best of my knowledge, I think it was Texas. I think.
    • SEEFER: And understanding that you’re not sure it was Texas, what were the concerns?
    • SULLIVAN: Unfortunately, that’s one question too many. I simply can’t recall.
    • SEEFER: I mean let me try. Do you recall if their concerns were just too high a level of exposure?
    • SULLIVAN: I simply can’t recall.  
  • 2007 1205 – AIG – American International Group Investor Meeting – 518p
    • (p355)
      • Unidentified Audience Member – Hi. I just have a question on your portfolio — overall portfolio.
        • Based on the current environment, where is it that you’re buying more or increasing your relative bidding?
        • In terms of asset classes, where are you backing off?
        • And specifically on subprime RMBS, do you see an opportunity to increase the allocation to that asset class?
          • Or, are you trying to get rid of what you own?
      • Richard Scott – American International Group – SVP – Investments
        • One of the clear opportunities here is that if you believe, as we do, that the AAA sector of the RMBS market is money good and if you could truly buy those securities at significant discounts, there’s a huge opportunity.
        • And there’s a bit of resistance to catching the falling knife.
        • But on the other hand, we’ve got a long-term view.
        • And if we can buy that paper at meaningful discounts to par and have high confidence that we’re going to get paid back over the next three or four years, we should be buying a lot of that.
        • But as I say, not very much of it is trading. So –. 
      • Win Neuger – American International Group – EVP, Chief Investment Officer
        • Yes. I think there’s some short-term technicals to the market that would probably have me be a little cautious in the short run, including the fact that there’s some seasonals to delinquency patterns that typically peak in the first quarter of the quarter of the year, which I think are going to lead to some more fun headlines before we get out of the woods.
        • So realistically from a tactical viewpoint, I’m probably in a neutral position right now.
  • 2010 0701 – FCIC – Hearing – 2008 Financial Crisis and Derivatives, Day 2, Regulators Panel 
    • Testimony – Dinallo – Superintendent of the New York State Insurance Department – 20p
      • As early as July 2006, the New York Department and other state regulators were engaged in discussions about the securities lending program with AIG.
      • Those discussions at first related to the issue of risk-based capital and how the companies were reporting their securities lending program on their financial statements.
      •  It was in the course of those discussions that we learned about the details of AIG’s securities lending program.
    • Beginning in 2007… …we insisted that the program be wound down and…
    • Neither the NYSID nor any other state regulator issued a written directive to AIG to wind down the securities lending business.
      • The lack of a directive is not unusual.
      • Also, in the case of securities lending, raising written (and thus public) questions about the program could cause counterparties to contractually end the loans (versus continuing to roll over the loans) and cause forced sales and losses.
    • From its peak of about $76 billion it had declined by$18 billion, or about 24 percent, to about $58 billion by September 12, 2008.
    • At that point, the crisis caused by Financial Products caused the equivalent of a run on the AIG securities lending program.
      • Borrowers that had usually rolled over their positions from period to period began returning the borrowed securities and demanding their cash collateral.
      • From September 12 to September 30, borrowers demanded a return of about $24 billion in cash.
    • There are two essential points about AIG and its securities lending program.
      • First, without the crisis caused by Financial Products, there is no reason to believe there would have been a run on the securities lending program.
    • Indeed, before September 12, 2008, the parent company contributed slightly more than $5 billion to the reduction of the securities lending program.
    • Whatever the problems at securities lending, they would not have caused the crisis that brought down AIG.
    • On July 21, 2008, New York issued Circular Letter 16 to all companies doing business in New York which expressed Department concerns about security lending programs.
    • On September 22, 2008, the Department sent a Section 308 letter to all life insurance companies licensed in New York requiring them to submit information relating to security lending programs, financing arrangements, security impairment issues and other liquidity issues.’
      • (Section 308 is the provision of the NYS Insurance Law that gives the Department the authority to request additional information between periodic examinations.)
    • Through our chairmanship of the National Association of Insurance Commissioners Statutory Accounting Practices Working Group, we also successfully worked to have the NAIC adopt increased disclosure rules for securities lending programs.
    • And it is worth noting that it was only AIG that was using securities lending in such a risky manner.
    • <more>

Mortality Tables

  • The mortality table is the instrument by means of which are measured the probabilities of death and survival.

1940-Supplement NAIC Proceedings 

  • 1919 – Book – Sources and characteristics of the principal mortality tables, by Henry Moir – 98p
    • The Actuarial Society of America
  • It should be remembered that the CET Table was prepared to enable companies to charge a proper rate for extended term coverage.

—  Elgin R. Batho

1961 – SOA – Premiums – Digest of Small Company Forum, tsa61v13pt2d44 – Society of Actuaries – 9p

ERM – Enterprise Risk Management

  • 2010 – SOA – Did Enterprise Risk Management Really Work? – The Case of Lincoln Financial Corporation, Scott Engle, Presented at 2010 Enterprise Risk Management Symposium, mono-2010-m-as10-1-engle – Society of Actuaries – 18p
  • 2013 – SOA – ERM-ILA Model Solutions, Fall 2013, edu-2013-10-erm-ila-exam-sol-wt66id – Society of Acuaries – 38p
    • Learning Objectives:
      • 2. The candidate will understand the concepts of risk modeling and be able to evaluate and understand the importance of risk models.
      • 4. The candidate will understand the approaches for managing risks and how an entity makes decisions about appropriate techniques.
    • Pricing Risk:
      • o Consumer behavior is partially dependent upon product performance, which is contingent upon market performance.

Resolution Authority

  • 2008 0710 – GOV (House) – Systemic Risk and the Financial Markets, CSPAN – Transformation of Financial Markets
    • [PDF-86p, VIDEO-CSPAN] – <mp3, mp4>
    • Paulson, Bernanke
    • 1:17:30 – Paulson – need resolutions authority like FDIC
  • The lack of an appropriate regulatory regime and resolution authority for large nonbank financial institutions contributed to this crisis and will continue to constrain our capacity to address future crises.  (p7)

— Timothy F. Geithner, Secretary, U.S Department of the Treasury 

2009 0324 – GOV (House) – Oversight of the Federal Government’s Intervention at American International Group – [PDF-91p, VIDEO-CSPAN] – <mp3, mp4>

  • Geithner and Bernanke Testimony on AIG Bonuses 
  • House – Committee on Financial Services
  • Fed Window
  • Richard Scott, FCIC MP3 Interview
  • 2014 04 – Book – Modernizing Insurance Regulation – John H. Biggs, Matthew P. Richardson – 304p
  • 2020 0825 – FSB – Key Attributes Assessment Methodology for the Insurance Sector – 72p
  • NAIC
    • GUARANTY FUNDS
    • NAIC Insurer Receivership Model Act
  • 2009 0924 – GOV (Senate) – Systemic Risk and Resolution Issues / Experts’ Perspectives on Systemic Risk and Resolution Issues – [PDF-128p,  VIDEO-CSPAN]
    • (p7) – Paul Volcker – “…..insurance companies, which I would say parenthetically I hope better regulatory systems will be developed, maybe not as part of this legislation but next year.”  
    • (p19) – Paul Volcker – “I would hope this committee would look at the question of national charters for insurance companies and bring them under-at least the big ones-under a framework so that something like AIG with similar problems can’t arise in the future.”  
    • (p49) – Ed PERLMUTTER (D-CO) – How do we resolve insurance companies?
      • Do you know?
      • We liquidate them through the insurance commissioner.  
  • (p25) – Senator Bob CORKER (R-TN) –  Well, it may not-I think this whole issue of authority is pretty incredible, and I think all of us realize that the Fed nor anyone else has the authority not only to deal with AIG but Citigroup or Bank-there is nobody.
    • I mean, I think that is an amazing thing that for some reason only hits my alarm bell, nobody else’s.
    • But there is no entity in our country that has the ability to deal with an AIG, a Citigroup, a Bank of America, anybody.
    • I find that pretty incredible. 

2009 0305 – GOV (Senate) – American International Group: Examining What Went Wrong, Government Intervention, And Implications for Future Regulation – CSPAN- Government Intervention and Regulation of AIG – [PDF-72p]

AIG – Securities Lending – Insurance Regulators

  • (18) – Baxter: When you look at what happened with AIG’s securities borrowing program, in a nutshell, AIG’s insurance companies held Treasury securities, which they lent out for cash.
    • Then they used that cash to buy MBS, knowing that in the future they would have to sell the MBS to then redeem their Treasuries.
      • No supervisor stepped up and said, “Wait a minute. You’re making a play for yield, you’re putting yourself at risk of being illiquid,” which is exactly what happened.
    • But we didn’t feel free to discuss this supervisory failure.
      • We felt freer to talk about Financial Products.
    • If you’re a federal official and it looks like you’re being critical of the state official, that can be a bad position to be in. 

2018 1120 – Lessons Learned Oral History Project Interview: Thomas Baxter – 19p

  • (p9) – Susan Voss: And perhaps the greatest single source of concern for the insurance regulators during the financial crisis was securities lending activities by AIG. 
    • Commissioner, Iowa Insurance Division, and President, National Association of Insurance Commissioners (NAIC), on behalf of NAIC

2011 0728 and 1025 – GOV (House) – Insurance Oversight: Policy Implications for U.S. Consumers, Businesses and Jobs – Part 1 (2011 0728), Part 2 (2011 1025), Judy Biggert (R-IL) – [PDF-285p, VIDEO-?]

  • Eric Dinallo – New York
  • Terri Vaughan – CEO NAIC / Iowa
  • Michael Mcraith – Illinois
    • Insurance and Systemic Risk – [PDF-181p, VIDEO-CSPAN]
  • Sandy Praeger
    • Kansas Insurance Commissioner
    • 2008 – NAIC President
  • Doug Slape – Texas – AIG Lead Regulator
  • content.naic.org/sites/default/files/capital-markets-primer-securities-lending.pdf
    • While this insurer is most known for significant losses that occurred within its credit default swap (CDS) program, the onset of an overwhelming demand for returned cash by its securities lending counterparties compounded the insurer’s liquidity constraints.
  • 1:08-cv-05722 – American International Group, Inc. ERISA Litigation II
    • 2012 – Document 137 – Consolidated Second Amended Complaint – 230p
  • 2008 1010 – WSJ – AIG Increases Borrowings While Racing to Sell Assets, By Liam Pleven, Carrick Mollenkamp and Craig Karmin –  Oct. 10, 2008 – [link]
    • Securities Lending
    • 2009 0305 – GOV – Perspectives on Systemic Risk
  • As early as July 2006, we were engaged in discussions about the securities lending program with AIG.
  • In 2007, we began working with the company to start winding down the program.

2010 0526 – COP – Testimony – Michael Moriarty, Deputy Superintendent of the New York State Insurance Department – 7p

  • In December 2006, AIG’s lead state insurance regulator for the company’s domestic life insurers (“lead life insurance regulator”) began a routine examination of AIG in coordination with several other state regulators.19
    • During the examination, the state regulators identified issues related to the company’s securities lending program.
    • Prior to mid-2007, state regulators had not identified losses in the securities lending program, and the lead life insurance regulator had reviewed the program without major concerns.

2011 09 – GAO – Review of Federal Reserve System Financial Assistance to American International Group, Inc – 152p

  • 2008 0721 – Circular Letter No. 16 (2008) – [link]
  • TO: All Authorized Insurers, RE: Securities Lending
  • STATUTORY REFERENCE: N.Y. Insurance Law §§ 201, 301, 1409 and 1411
    • It has come to the Department’s attention that some insurers engaged in securities lending activity have experienced significant losses in the last six to twelve months.
      • Specifically, cash received as collateral was reinvested into securities whose value has significantly declined.
      • As we see increased volumes in securities lending activity, we are concerned that some insurers may not be maintaining adequate collateral and effectively managing the risks associated with the securities lending function.

DOL – Fiduciary Rule

  • 2016 04 – DOL – Regulating Advice Markets Definition of the Term “Fiduciary” Conflicts of Interest Retirement Investment Advice Regulatory Impact Analysis For Final Rule And Exemptions, Department of Labor – 395p
  • 2016 – Legal Cases
    • 2016 – LC – ACLI vs. Perez (DOL – Department of Labor) – Fiduciary Rule – Case 3:16-cv-01476-M – Perez, District Court Northern Texas  —  [BonkNote]
    • 2016 – LC – Chamber Of Commerce of the United States of America et al. v. Perez et al., Civil Action No. 16-cv-1476 (N.D. Tex., filed June 1, 2016) (Lynn, C.J.);
    • 2016 – LC – National Association for Fixed Annuities v. Perez et al., Civil Action No. 16-cv-1035, (D.D.C., filed June 2, 2016) (Moss, J.); and
    • 2016 – LC – Market Synergy Group, Inc. v. United States Department of Labor et al., Civil Action No. 16-cv-4083 (D. Kan., filed June 8, 2016)
  • 2022 0407 – 2022-1, NAIC Proceedings –  LIAC – Life Insurance (A) Committee
    • 3. Heard a Federal Update on the Implications of the DOL Fiduciary Rule – Brooke Stringer (NAIC)
      • Patrick C. Reeder, American Council of Life Insurers-ACLI … said a fiduciary standard is not a bad standard, and it is an appropriate legal standard for situations where there is an ongoing relationship providing financial advice.
        • He said the problem with the DOL proposal is that it is a fiduciary-only approach, which would eliminate commission-based sales; i.e., the way that lower and mid-range clients buy products.
        • He said the DOL should recognize the changes that have taken place since 2017.
        • He said both the SEC’s Regulation Best Interest standard and the NAIC best interest revisions to the Suitability in Annuity Transactions Model Regulation (#275) provide a strong standard of care that is vigorously enforced.
        • He said state insurance regulators have a strong story to tell, and the DOL needs to hear from the NAIC.
      • Micah Hauptman (Consumer Federation of America-CFA) said there are gaps in the current regulatory framework.
        • He said he does not believe consumers’ reasonable expectations are being met.
        • He said the DOL should require a fiduciary duty, regardless of what products are being sold or how they are being sold.
        • He said consumers all expect and deserve high quality advice without the taint of conflicts of interest.