3.11.12. Communications Regarding Variable Insurance Products
FINRA has several rules that apply specifically to communications involving variable annuities and variable life insurance policies.
• The communication must clearly describe the product as a variable annuity or a variable life insurance policy. Because of the differences between variable products and mutual funds, the communication cannot imply that the product is a mutual fund.
• The communication cannot indicate that the product is a short-term or liquid investment because variable products often come with surrender charges and penalties for early withdrawals.
• The communication must not exaggerate the safety of guarantees (e.g., guaranteed minimum death benefit or a guaranteed schedule of payments). After all, insurance companies can go out of business and not pay out claims. Nor can the communication guarantee an investment re