How should suspicious activity involving variable insurance products funded by separate accounts that meet definition of a mutual fund be reported?
Some insurance companies issue variable insurance products funded by separate accounts, some of which meet the definition of a mutual fund.3 We are in the process of finalizing a rule that would require mutual funds to themselves file suspicious activity reports. When that final rule becomes effective, we will amend the insurance company suspicious activity reporting rule to ensure that such suspicious activity is reported under the mutual fund rule. Until such time as a final rule requiring suspicious activity reporting by mutual funds is adopted, however, insurance companies that issue variable insurance products funded by separate accounts that meet the definition of a mutual fund may report suspicious activity on FinCEN Form 101 Suspicious Activity Report by Securities and Futures Industries.
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