Vedder Price

Vedder Thinking | Articles Remarks of Dalia Blass at the ALI CLE 2019 Conference on Life Insurance Company Products


Reader View

On November 7, 2019, Dalia Blass, Director of the SEC’s Division of Investment Management, delivered the keynote address at the annual ALI CLE Conference on Life Insurance Company Products. Her remarks primarily focused on the staff’s rulemaking activity over the prior year. Ms. Blass discussed comments received on the SEC’s proposal to permit issuers of variable contracts to use a summary prospectus. She stated that significant comments had been received on the treatment of discontinued contracts, the use of structured data using inline XBRL tagging and the proposed use of standardized terminology in disclosure documents. She stated that a final rule was expected by April 2020. Ms. Blass also discussed the SEC’s recent proposal to modernize the investment adviser advertising and solicitation rules, noting that the proposed rule “recognizes the evolution of the market place and how investors look for and receive information” since the adoption of the original rule. Ms. Blass pointed to the recent adoption of the ETF rule and the expedited review process for certain exemptive applications as initiatives that the staff hoped would create more investment options for investors by reducing costs for sponsors. Ms. Blass concluded her remarks by noting that the staff’s recent regulatory initiatives have been part of the staff’s ongoing focus on protecting investors, improving the investor experience and modernizing the regulatory framework.

A transcript of Ms. Blass’s remarks is available here.


Nathaniel Segal


Jacob C. Tiedt


John S. Marten