Advise insurance companies and insurance distributors in areas of variable annuity, variable life, modified guaranteed annuity, and other insurance product development, administration, and distribution, including compliance with applicable federal securities laws, federal tax laws, and state insurance laws. Draft policy forms for filing and approval. Draft third party administration service agreements. Provide legal counsel in connection with insurance holding company transactions. Advise insurance companies on transfers of blocks of business. Provide legal advice in connection with insurance company insolvencies, limited lines insurance, and surplus lines insurance. Represent insurance companies and distributors in connection with state insurance examinations and regulatory matters, and SEC and FINRA examinations. Draft and negotiate distribution agreements. Advise in establishment of compliance policies and procedures, including sales practices and sales supervision, audits, surveillance, and training.
Served as Senior Vice President and General Counsel to Merrill Lynch Life Insurance Company and ML Life Insurance Company of New York, 1990-2007. Served as Chief Compliance Officer to MLIG Variable Insurance Trust, New Jersey, and Roszel Advisors, LLC, New Jersey, 2005-2008. Served as First Vice President and Assistant General Counsel to Merrill Lynch, Pierce, Fenner & Smith Inc., New York, NY, 1991-2008 and as Senior Counsel to Merrill Lynch, Pierce, Fenner & Smith Inc. from 1984 to 1990. Served as Assistant General Counsel to National Benefit Life Insurance Company, New York, NY, 1983-1984. Served as Assistant Counsel to Manhattan Life Insurance Company, New York, NY, 1979-1983.