August 28, 2008
I’m writing today to ask for an extension for the comments of SEC rule 151A.
For the past 7 years or so, my company has made a living on Equity Indexed Annuities. We obviously are affiliated with a member broker dealer also, so we sell both securities and insurance products. It creates a recession proof business, and is good for our customers.
Index annuities are the perfect product for market risk and deferred taxes. This rule, I believe, hasn’t been fully thought through, and may not have basic legal support. I urge you to reconsider, and extend the comment time frame to get a fully accurate representation from the experts in our field. How can a EIA be a security when there is no downside risk for the consumer?? This extra oversight will only add to the costs of operation, and not protect consumers any more than the insurance industry already does. We fill out more paperwork for an annuity sale than a security sale these days due to all the disclosures involved. It sure seems you, the SEC, is pushing this thru before everything has been combed thru. Please consider the costs involved of implementation of such rules and regulations to the industry as a whole. It will only trickle down to inferior products for the consumers…
Thanks for considering an extension to this hastily drawn up rule.
DeWayne C. Soares
Soares and Associates