Dec 05, 2016
From the Financial Reporting View
The SEC staff recently issued a no action letter that allowed a sponsor of variable products to include statutory financial statements instead of U.S. GAAP financial statements in a Form S-1 filed to register insurance products. The staff required the insurance products registered using Form S-1 to have virtually identical benefits to the benefits of insurance products that the sponsor offered on Form N-4. The SEC staff stated that it would be receptive to similar requests for relief from other sponsors having similar circumstances for financial statements to be included in a registration statement on Form S-1 or Form S-3.