August 28, 2008
I am a licensed insurance professional as well as a registered rep. and I am writing to you to urge you to withdraw this proposed rule.
Index annuities are not securities and should not be classified as such.
I have clients who have been sold index annuities that were inappropriate for them. The product they were sold were miss- represented and have worked a financial hardship on them.
I do feel each state needs to adopt and aggressively enforce the NAIC'S model regulations on annuity suitability and disclosure. There needs to be more oversight in this area but I don't feel Rule 151A is the answer. This product is not a security. It is an insurance product and its regulations and enforcement of said should continue to be provided by the state's insurance regulatory structure.
Please withdraw this proposed rule.
Tom Rountree CLU ChFC MSFS
Tom Rountree,CLU ChFC
Associates in Financial Planning