The Annuity Buyer's Guide Hasn't Changed Since 2013. Here's What's Being Added.
The annuity buyer's guide hasn't changed since 2013. Here's what regulators are adding.
Regulators are rewriting the standard consumer guide handed out with annuity sales for the first time since 2013 — and insurers and consumer advocates don't agree on how direct it should be.
Every state makes a standardized Buyer's Guide available to consumers shopping for a deferred annuity, as required by the National Association of Insurance Commissioners (NAIC). The version currently in circulation was last revised in 2013.
Thirteen years is a long time in this product category. Registered index-linked annuities (RILAs) did not exist as a mainstream category in 2013. Persistency bonuses were far less common. The state-level best interest standard for annuity recommendations had not yet been adopted nationwide. None of that is covered in the document a buyer is handed today.
In late 2025, NAIC formed the Annuity Buyer's Guide (A) Working Group specifically to close that gap — and the process of doing it has turned into a real disagreement between industry and consumer advocates about how the guide should read.
That disagreement matters more than it might first appear. A buyer's guide isn't a marketing document and it isn't a sales script. It's the one piece of standardized paper a regulator requires every buyer to see before money changes hands, regardless of which carrier, which agent, or which state they're in. Whatever the final version says — or doesn't say — about MVAs, riders, and bonuses becomes the floor of what every annuity buyer in the country is assumed to understand going in.
The scale of the shift the 2013 guide missed is easy to understate. Fixed indexed annuities grew from roughly 24% of total annuity sales in 2015 to 45% by 2025. Registered index-linked annuities set a quarterly sales record of $23.3 billion in Q2 2026 alone — a category that was a rounding error, if it existed at all, when the current guide was written. A document meant to orient a first-time buyer has been describing a market that, by dollar volume, is less than half the one actually being sold to them today.
A Document That Predates Most of Today's Annuities
The 2013 version has no language for what's actually being sold in 2026
A consumer handed the 2013 guide today gets no section explaining a market value adjustment (MVA), no mention of RILAs, and no plain-language walkthrough of guaranteed living benefit riders beyond the most basic withdrawal rider. All three are present in a meaningful share of annuity contracts sold right now.
Worked example: A buyer purchases a fixed indexed annuity with an MVA and needs to withdraw more than the penalty-free amount three years in, after interest rates have risen since purchase. The MVA formula can reduce the surrender value below what the buyer assumed — a mechanic the 2013 guide never explains, because the feature wasn't common enough in 2013 to warrant a section.
The working group's charge is explicit
NAIC's Annuity Buyer's Guide (A) Working Group, formed in late 2025, was charged to "review and revise the NAIC Buyer's Guides for Deferred Annuities in light of changes in the marketplace" (NAIC Annuity Buyer's Guide (A) Working Group, 2026). That's a direct acknowledgment that the current guide no longer matches the current market.
A second gap: the regulatory backdrop has also changed
The 2013 guide also predates the nationwide rollout of a stronger consumer protection. More than 40 states now apply the updated NAIC best interest standard to annuity recommendations, under the Suitability in Annuity Transactions Model Regulation — a framework that didn't exist in its current form when the buyer's guide was last written. A revised guide gives regulators a chance to explain that standard directly to the people it's meant to protect, instead of leaving it as a fact buyers have to discover elsewhere.
Put together, the working group isn't just adding glossary entries for new products. It's trying to close two gaps at once: a product gap (what's actually being sold) and a protections gap (what rules now govern how it's sold). Neither existed in its current form in 2013.
What the New Draft Adds
Two drafts, two comment periods, four new topics the 2013 guide never covered.
The working group released its first full draft for public comment on March 16, 2026, with comments due April 16, 2026. A revised draft followed on August 3, 2026, with a second comment period that closed September 18, 2026 (NAIC Annuity Buyer's Guide (A) Working Group, 2026).
The new sections cover market value adjustments and how they can increase or decrease the amount available on an early withdrawal depending on interest-rate movement since purchase; guaranteed living benefits beyond the simple withdrawal rider, including step-up and income-base features; persistency bonuses and other credit-based incentives tied to how long a contract stays in force; and registered index-linked annuities, which didn't need their own buyer's-guide section in 2013 because they barely existed as a product.
None of this is optional reading for someone comparing products today. MVAs and income-base riders in particular can materially change what a contract actually pays out if it's accessed early, or structured differently than a buyer assumed going in.
Take the income-base distinction specifically: a guaranteed living benefit rider typically tracks a separate "benefit base" that is used only to calculate guaranteed withdrawal amounts, not a cash value a buyer can withdraw in full. That base can grow on a schedule unrelated to the contract's actual account value, and the annual rider fee is charged regardless of market performance. A 2013-era guide that never mentions a benefit base leaves a buyer with no framework for understanding why the number quoted at the sales table isn't the number sitting in the account.
Persistency bonuses raise a parallel issue. A bonus credited for keeping a contract in force past a certain anniversary can make an early surrender more expensive than the stated surrender charge alone would suggest, since giving up the bonus is its own cost on top of any penalty. None of that math shows up anywhere in the current guide, and a buyer relying on it alone has no way to even know the question is worth asking.
Market value adjustments and their impact on early withdrawals
Guaranteed living benefits beyond basic withdrawal riders
Persistency bonuses and other credit-based incentives
Registered index-linked annuities (RILAs)
Why Insurers Pushed Back on the Tone
Industry and consumer advocates agree the guide needs updating. They disagree sharply on how direct it should be.
After the March 2026 draft circulated for comment, three distinct positions emerged in the public record — and none of them simply argue the guide shouldn't change. The fight is over how plainly it should describe the risks.
Industry: keep it neutral
After the March draft circulated, the National Association for Fixed Annuities, through general counsel Pam Heinrich, said "the tone and tenor of the guide is perhaps unnecessarily negative." The American Council of Life Insurers, through counsel Madison Ward, asked for "adjustments to tone and framing...to ensure that the buyer's guide remains neutral and educational" (InsuranceNewsNet, 2026).
Consumer advocates: inform before, not after
University of Georgia consumer economics professor Brenda Cude, a longtime NAIC consumer representative, pushed back with a behavioral point: "once people have made the psychological decision to purchase something, they're far less interested in information that might lead them to question their decision." Her argument is that the guide's job is to inform the decision before it's made — not soften it after (InsuranceNewsNet, 2026).
Regulators: balance and brevity
Regulator Danielle Torres pushed for simplicity alongside balance, saying the group "should still work to simplify and shorten the document so that it's clear and digestible" (InsuranceNewsNet, 2026) — a reminder that a longer, more complete guide isn't automatically a more useful one if nobody reads past page one.
What This Means If You're Shopping for an Annuity Right Now
The 2013 guide is still the one in circulation. There's no fixed date for when a final revision takes its place.
A smaller drafting group, made up primarily of state regulators, is now working through the September comment round to produce a further revised draft. Until that process finishes, the questions it's trying to answer are still worth asking directly — in person, before signing anything.
- Does this contract have a market value adjustment?
- Under what conditions does it apply to a withdrawal?
- Could it reduce what I can access, not just increase it?
- What exactly triggers the guaranteed living benefit?
- What does it cost as an ongoing annual fee?
- Does the income base grow, and under what conditions?
- Is there a persistency bonus built into this contract?
- What do I give up if I surrender early to keep it?
- Is the bonus guaranteed or conditional on performance?
An Updated Guide Still Isn't a Substitute for Independent Advice
A revised NAIC buyer's guide, whenever it's finalized, will be a better baseline than the 2013 version. But it's a generic document covering an entire product category, not an analysis of any specific contract.
The best interest standard now in place in most states requires the person recommending an annuity to act in the client's interest. That doesn't substitute for a buyer independently verifying the specific terms: surrender schedule, MVA formula, rider costs, and renewal rate mechanics vary by carrier and contract, not by category.
A best interest standard is also a conduct rule, not a disclosure rule. It governs how a recommendation is made; it doesn't automatically translate into a buyer understanding every mechanic inside the contract they're being recommended. Those are two different protections, and a buyer who only relies on the first one is still exposed on the second — which is exactly the exposure a clearer buyer's guide, and a vetted advisor willing to walk through the actual contract, are both meant to close.
This is the structural reason AHQ exists as a research-first, advisor-matching resource rather than a sales channel. A reader shouldn't need to wait for a 2027 or 2028 NAIC revision to get a straight answer about a contract being offered to them today.
It's also worth sitting with why this revision took until 2025 to start. Buyer's guides are consensus documents, built by a working group that includes regulators, industry trade groups, and consumer representatives in the same room. The tone fight playing out between the National Association for Fixed Annuities and Brenda Cude isn't a side issue slowing down an otherwise simple update — it's the actual mechanism by which the document gets written, and it's a large part of why thirteen years passed between revisions in the first place.
Common Questions
1 When was the NAIC Annuity Buyer's Guide last updated before this revision? ▼
2 What is a market value adjustment (MVA) and why is it being added to the guide? ▼
3 Why did insurance industry groups object to the draft guide? ▼
4 Is the new buyer's guide final yet? ▼
5 Does a NAIC buyer's guide replace the need for an independent advisor? ▼
6 What should I ask about if I'm shopping for an annuity before the new guide is finalized? ▼
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