September 5, 2008
As a professional in the insurance industry for close to ten years, I am opposed to Proposed Rule 151A. I disagree strongly that it will provide the consumer added protection it will only add additional cost to the end user. I believe that additional oversight by the SEC would be redundant, as indexed annuities are already heavily regulated by the insurance industry. This oversight includes but is not limited to: reviews of financial suitability of recommendations, full annuity disclosure and advertising compliance, agent licensing and training, enforcement actions and penalties for noncompliance with sale practice requirements. Furthermore, fixed indexed annuity products offer significant protection to the consumer against investment risk. The DJIA has posted a decline of over 20% this year (from October 2007). Conversely, a consumer who owned a fixed indexed annuity would not have lost any principal or any prior credited interest. The SEC should stick to the oversight of the financial instruments that expose the consumer's investment to risk and stay clear of the financial products that do not. With all these considerations, I fail to see why the SEC feels it necessary to enter into this arena. Please add my voice to those who strongly oppose Proposed Rule 151 A.