August 27, 2008
Dear Sirs:
As a financial professional with 33 years of client based service I consider myself ethical and client oriented. I further feel that dishonest and unscrupulous individuals in our industry should be punished to the fullest extent of the law.
Having said that, I believe this proposed regulation to require SEC/FINRA registration for sales of Indexed Annuities is not warranted. Regulation of these products should remain with individual states and be strictly monitored. As professionals we do not need another layer of bureaucratic controls / paperwork to contend with. As this is an insurance product it should not be regulated by the broker/dealer, creating more paperwork for the producer and less commission – yes the B/D will take a portion of our income without need. Further, once so regulated, fixed annuities will be regulated by the B/D costing the producer even more.
I strongly urge you to withdraw this proposal.
William C. Fallon, CLU, ChFC
Licensed Insurance Advisor
Sullivan Garrity & Donnelly