Led by the Consumer Federation of America (CFA), a coalition of consumer and union groups submitted comments to the National Association of Insurance Commissioners (NAIC) urging amendments to NAIC's Suitability in Annuity Transactions Model to protect consumers.

In the comments, the advocates argue that insurers and producers should be required to act in the best interests of consumers, best interest standard provisions must be stronger, and the best interest standards must include substantive prohibitions on conflicts of interest.

The consumer and union groups were AFL-CIO, Americans for Financial Reform Better Markets, Center for Economic Justice, Consumer Action, Consumers Union, Consumer Federation of America, EPI Policy Center, National Consumers League, National Employment Law Project, Pension Rights Center, UnidosUS (formerly NCLR), U.S. PIRG, and the Woodstock Institute.