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Deleted - old info - sorry.
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Hasn't ended B/Ds requiring their Reps to submit FIAs to Securities suitability and submitting the business through the B/D.
My BD doesn't require they be submitted through them. They only want to know what carriers their reps have done business with and which products. Of course, you also have to disclose this type of business on the OBA form.
Let me delete my answer in advance.
Rick