September 2, 2008
-The design amd sale of annuities are highly regulated by state insurance departments as are the companies who manufacture and sell them. Guaranteed mimimum values for annuities are regulated through the Standard Nonforfeiture Law and are applicable to ALL fixed annuities.
A new securities regulation will add little benefit to consumer protection. Many state have already adopted the NAIC Annuity Disclosure Model Regulation and most companies have disclosure statements for each product.
Guarantees offered by annuities provide significant consurmer protection against investment rick which securities do not.
Please do not adopt this unnecessary rule that does not help the consumer.