In their recent article discussing suitability standards for annuity transactions, Pompano Beach attorneys Norse Blazzard and Judith Hasenauer mention a compliance officer they know who reviews annuity sales with the suitability standard of “would I want my mother to purchase this annuity?”  According to a recent American Council of Life Insurers tally 15 states have adopted the suitability standards set forth in the National Association of Insurance Commissioner’s Senior Protection in Annuity Transactions Model Regulation and the NAIC model has been proposed in 11 additional jurisdictions. Other states have implemented more rigorous suitability standards. The recent increase in litigation against insurers and producers over the sales of various types of annuities therefore comes as no surprise. What is troublesome is the ease with which courts are adopting suitability as the duty that insurers owe to their annuity customers when state insurance regulations do not by their terms provide for private rights of action by annuity purchasers. Perhaps Blazzard and Hasenauer are correct--with courts relying upon suitability standards and procedures that are in a clear state of flux, the “mother” standard may be as valid as any other.