September 4, 2008
As an independent insurance agent, we already have significant regulation from the overseeing state insurance regulating entities that control our activities with the public.
The equity indexed annuity product is one of the best investment vehicles that is available to investors today and it already protects the investor from market downside risk, unlike investments in securities alone. Consumers are seeking ways to protect their retirement nest-eggs and this is an excellent vehicle to so just that.
The design and sale of annuities is already highly regulated by state insurance departments as are the companies that provide them. These include the suitability statements, disclosures about surrender periods, and lots of regulation about unfair trade practices.
Additional regulation by the SEC will add little benefit to consumer protection, but it would have an adverse impact on how the existing products are currently marketed and sold by independent agents like myself. I would encourage you to work with State Insurance agencies to shore up the existing and proposed disclosure, suitability and sales practice laws instead of adding another level of regulation and the elimination of the sale this product from independent agents like myself.
Sincerely,
Nathan Schnurman