"The preamble to the direct final rule explains that '[a]lthough the statutory safe harbor did not technically nullify or repeal the regulatory safe harbor, its existence offers an unnecessary and inefficient alternative and may inadvertently be a trap for the unwary.' On a closer read, however, the differences between the safe harbors may in fact be significant and far from noncontroversial. In divergence from the purpose of both safe harbors, the removal of the regulatory safe harbor may create a gap that could have the effect of chilling annuity sales going forward."  MORE >>