"Regulators’ desire to hold insurance companies accountable for their sales practices and the practices of those producers contracted to sell for them is becoming more and more popular. Even though Minnesota law is vague when it comes to defining suitability, or what specific “reasonable grounds” are required for a company or producer to believe the annuity product being sold is suitable for the consumer, this settlement agreement sets out guidelines for what may be expected when selling these products, not only in Minnesota but elsewhere. . . . .  One has to think that juries will tend to fall on the side of the consumer against the insurance company. That is just the optics. As one who has been involved in the regulatory and legislative processes, sometimes laws and regulations are often drafted vaguely. Right or wrong, this is done so that the powers of regulators are expanded over the regulated, so that overarching settlements like the Allianz agreement can be achieved.  . . . . One important lesson to be taken from this settlement," Poolman continues, "is that regardless of what the internal processes are in place for insurance companies to determine suitability, there should be constant review of these policies and procedures. Gathering more information from applicants rather than less can be a strong defense against a mandate to retroactively determine whether or not a product was suitable, as is prescribed in the Allianz settlement."