September 6, 2008
Dear Commissioner:
I believe the SEC Rule 151A is very unsound, unethichal and unnecessary for the following reasons.First, For the past 12 plus years, I have been selling Equity Indexed FIA annuities which have protected the iunterest of thge consumers principle gains when the Market is down. Also, it has been the most cost effective financial arrangement for consumers overall, because unlike securities, the are
an Insurance annuity product with fine benefits and a guaurantee that there will be no loss to previous gains in the annuity product when the markets take a down turn.
This product has never been and never will be designed like a regular Security in that previous gains are never lost
Second, if you review the overall complaint ratio from Agents who have sold FIA,s the complaint ratio with the respective State Department of Insurance Bureaus have been extremely low.
Third, If consumers lose this valuable product and Licensed Insurance Companies lose this product, then
Securties Dealer Brokers gain higher commissions, fees etc and leave the consumer with no choice to purchase these products that work very well for them.
Fourth,when consumers need to withdraw funds, they do have liquid withdrawals available and tax deferral available on the interest while the funds are seting there drawinbg interest.
PLEASE RESPECTFULLY RE-CONSIDER THIS SEC RULING BEFORE IT RUINS THE CONSUMER, THE AGENTS AND THE RESPECTIVE COMPANIES. I HAVE ALREADY WRITTIEN LETTERS TO MY CONGRESSMEN ANDSENATORS AS WELL TO EXPRESS MY CONCERNS
THAT THIS BE RE-CONSIDERED BEFORE IT GOES TO FAR AND WILL ONLY ALLOW SECURITES COMPANIES AND SECURITY BROKER DEALERS TO MAKE MORE MONEY AND ALLOW CONSUMERS TO LOSE VALUABLE BENEFITS FROM AN FIA.
CHARLES LEHTINEN