The VSA was launched in 1995 and has grown to become "the most comprehensive sales support tool in the industry." From the beginning, we have taken great care to make certain all of our material is "in compliance." We have been aided in this effort by the broker-dealer compliance departments of many of our clients.

However, in order to be absolutely sure of our position, we hired Financial Regulatory Services (formerly BISYS Regulatory Services) to have the entire contents of the VSA reviewed and submitted to FINRA (formerly NASD) in 2004-2005.  All FINRA-recommended changes to the content were made at that time.  We subsequently conducted a FINRA "renewal" review by resubmitting selected portions of the VSA content, as recommended by Financial Regulatory Services, in the summer of 2006.  The results for that review, together with the changes made to the content as a result of the review, are available below. Further, we have retained Financial Regulatory Services on an ongoing basis to review and, if appropriate, submit any new material to FINRA. 

1. August 28, 2006 FINRA (formerly NASD) Comment Letter
2. Summary of VSA Changes Made

We have some producers who seek approval on an "as used" basis. They simply e-mail presentations they have prepared for clients to their compliance officers and usually get same day approval for that individual piece. They provide their compliance department with a link to this page in advance in order to lend credibility to the compliance efforts and increase the compliance officer's comfort level in the overall product.

For additional insight, please contact our VP Compliance, Joan Barrett, CLU, ChFC.