Oversight of insurance professionals when selling insurance products registered with the Securities and Exchange Commission (SEC) is different than for other types of security products, the Association for Advanced Life Underwriting (AALU) says.

Their distinction should be taken into consideration by the SEC as it considers possible gaps in regulation, the AALU says in a comment letter on the agency’s proposed fiduciary standard.

“The scope and level of regulation is significantly higher for variable life insurance products than for other securities under the existing standard of care,” the AALU says in a comprehensive, 55-page response to the SEC request for comment.

“We believe consideration of the multiple layers of regulation and oversight of these variable insurance products, together with their product-specific requirements, should lead the SEC to conclude that no change in standards or further regulation is necessary,” the AALU letter said.

The group argued that the cost of meeting all regulatory and compliance obligations is already significant for all brokers, but especially for insurance producers,.

“An unwarranted change in standard that requires increased time and cost to comply could render the delivery of this service to middle-market clients too costly for insurance producers and their customers, resulting in limited access to insurance protection for millions of Americans,” the letter said.