September 3, 2008
Subject: File No. S7-19-07 From Virginia Lange
The concern of the SEC that the public is not being adequately protected by insurance agents in the sale of Indexed Annuities is completely misplaced. First, that State of Florida and Insurance commissions of other states have very strong regulation and guidelines to make sure that agents consider the suitability of such products for each client. Further, the carriers of these products themselves issue very thorough guidelines and material to make sure that agents inform their clients of the pros and cons of each product for their individual situations.
One has to suspect that greedy stock brokers, seeing much of their business slip away to these safer products, want a piece of the action. Historically, many of those brokers have shown no concern for preserving their clients' principal, only for increasing their own commissions by 'churning' their clients' accounts. All you will do by passing this regulation is to increase the burden on clients, agents, insurance companies, and create a larger and more expensive oversight structure without helping clients, and very probably, harming many of them Remember Sarbanes-Oxley and its unintended consequences? I urge you to think carefully before taking this dangerous step.