Industry objects to ‘tone and tenor’ of draft NAIC Annuity Buyer’s Guide

Industry trade groups are raising concerns about tone, timing and usability as work continues on a revised annuity buyer’s guide intended to help consumers better understand complex financial products.

The National Association of Insurance Commissioners' new Annuity Buyer’s Guide Working Group, formed late in 2025, held a Monday call to discuss draft changes meant to update the guide, last updated in 2013. Since then, new product innovations such as registered index-linked annuities have surged to the top of sales charts.

Proposed revisions focus on providing a more balanced view of annuity benefits and risks. Key additions include sections on:

• Market value adjustments and their impact on withdrawals.
• Guaranteed living benefits beyond simple withdrawal riders.
• Persistency bonuses and other complex product features not covered in the 2013 version.

But industry trade representatives voiced concerns over the language and general tenor of the draft changes.

“The tone and tenor of the guide is perhaps unnecessarily negative,” said Pam Heinrich, general counsel and director of government affairs for the National Association for Fixed Annuities.

The guide is delivered “after they've already chosen to purchase and apply for an annuity contract,” she added, noting that current “best interest” standards adopted in most states already require disclosures and conversations before a sale. Those standards were not in place when the buyer’s guide was initially adopted.

Other speakers noted that providing the document after a purchase decision may limit its usefulness, as consumers are less likely to reconsider their choices once they have been made.

“Once people have made the psychological decision to purchase something, they're far less interested in information that might lead them to question their decision,” said Brenda Cude, a veteran consumer liaison at the NAIC. “So that timing is really important.”

Push for clarity, simplicity

Across comments, a consistent theme emerged: the need to simplify the document without sacrificing essential information.

Cude, speaking for a letter also signed by consumer advocates Dick Weber and Bonnie Burns, said the goal should be to find “the sweet spot” between providing enough detail and avoiding overwhelming consumers.

“My assumption and my knowledge of how consumers seek information is it's a rare person who's going to start on page one and read through to the end,” Cude said. “They're going to skim it, looking for answers to the questions that they might have.”

Regulators from Maryland and Michigan also emphasized simplicity, saying the guide should serve as a general resource explaining basic concepts such as how annuities work and differences among product types.

“Our director just feels that we should still work to simplify and shorten the document so that it's clear and digestible to a consumer who's totally unfamiliar with annuities,” said Danielle Torres, representing the Michigan Department of Insurance and Financial Services.

Participants noted the inherent challenge, as annuities are complex products that often require nuanced explanations involving fees, tax treatment and optional features.

Debate over tone and content

Industry groups, including a coalition represented by the Insured Retirement Institute and the American Council of Life Insurers, said they are focused on maintaining the guide’s role as an educational tool for consumers.

“We suggest adjustments to tone and framing in the introduction and throughout the document to ensure that the buyer's guide remains neutral and educational and neither promotes nor discourages the use of annuities,” said Madison Ward, senior counsel for ACLI.

Some participants also questioned whether certain sections — such as repeated “ask about” questions across different annuity types — could be streamlined to improve readability.

Beyond content, participants highlighted the need to rethink how the guide is presented in a digital-first environment.

Several speakers said the traditional document format may not reflect how consumers now access information, suggesting mobile-friendly and searchable versions.

Next steps

Regulators overseeing the effort said they will form a drafting group to review comments and develop a revised version of the guide. The group will consist primarily of regulators, though additional participants may be invited to ensure a range of perspectives.

A second draft will be released for further comment.

Participants broadly agreed that while format and delivery are important, the immediate focus should remain on refining the content. Lauren Van Buren, chair of the working group and chief legal counsel for the Wisconsin Office of the Commissioner, was “thrilled” with the extensive comments on the draft.

“When there's a lot of engagement on these processes, I think that that does create a better work product in the end,” she said.

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InsuranceNewsNet Senior Editor John Hilton has covered business and other beats in more than 20 years of daily journalism. John may be reached at [email protected]. Follow him on Twitter @INNJohnH.