August 27, 2008
I also would agree with Mr Verhagen's analysis and opinion on the proposed rule. In my 28 years in this great business EIA's have caused as significant client confusion as any product. Important distinction should and needs to be made.
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----- Original Message -----
From: "Bill Verhagen"
Sent: 08/27/2008
To: rule-comments@sec.gov
Cc: Timothy Johnston
Subject: File number S7-14-08
I wish to voice my support for proposed Rule 151A. I am a licensed insurance professional along with being a Registered Representative and a Registered Investment Advisor.
In the past twenty two years that I have been in the financial services industry, I have come to appreciate the clear distinction of an insurance product and a securities product. Where these products are combined or where there is no a clear distinction to the investment public, I believe those products should fall within the scope of the proposed rule.
While the professional organization to which I belong, National Association of Insurance and Financial Advisors is against the proposed rule, I find that I must voice my support for the proposed rule.
My own experience is that Equity Index Annuities, while not a security and if properly marketed would not be confused with a security, are often explained to the consumer by people with no securities license. I have asked people who purchased these products from other advisors what they understood they were purchasing. Without exception, they all thought they were buying an investment that would behave the same as the underlying index.
I found not one consumer who understood the difference between point to point movement in an index versus the effective compounding of an index with dividend reinvestments. In fact, I have met agents who thought they were selling the index mutual fund with a floor.
It is because of my experience with clients who misunderstood the Equity Index Annuity products they purchased from others that I must voice my support for the proposed Rule 151A.
Bill
William R. Verhagen
CFP®, CPA, CFS, CLU®, ChFC®, CASL™
Innovative Financial Solutions, Inc.