August 28, 2008
Florence Harmon
Acting Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609
Florence Harmon:
I am a licensed insurance and financial services professional. I am writing to you because I do support the adoption of proposed Rule 151A, which would classify most indexed annuities as securities. Indexed annuity using securities related indexes as determining factors for overall product performance and therefore should be considered securities. Concerns about suitability, disclosure and marketing methods should be properly addressed by qualified individuals, who are properly licensed and/or bonded as required by law. I firmly believe that people who promote unsuitable sales and engage in misleading sales practices should be aggressively prosecuted and subject to meaningful sanctions. In my opinion indexed annuities shouldn't be treated as insurance products, and the state insurance regulatory structure is not the appropriate means for addressing the concerns raised by the FINRA and the SEC.
I urge the SEC to adapt the proposed rule. Thank you for your consideration of my views on this matter.
Sincerely,
Arkady Milgram