September 8, 2008
I believe the adoption of the proposed rule has the potential to have a negative impact not only for the insurance companies and agents, but consumers as well. These products are currently used by millions of Americans to help achieve their saving goals, particularly at a time when a growing number of our population is looking for ways to preserve and increase their retirement nest-eggs. The rule would add unnecessary and redundant disclosures to the sales process and would likely impair the availability of fixed indexed annuities. Making these products less available to the consumer would deprive many from accessing these products and their valuable principal guarantees.
I strongly support any effort to improve sales practices and I am committed to assisting my producers in insuring that all sales are suitable for the consumer. However, I believe the proposed rule is an unnecessary federal regulation and ignores state insurance suitability requirements now in place in more than 35 jurisdictions.
I firmly believe that current and pending state insurance disclosures, suitability and sales practice protection laws including regulations are quite adequate to protect the consumer. I need you to hear my concern for the thousands of small business owners and constituents that will be affected by this far-sweeping proposed rule.
On my behalf, please VOTE NO for the proposed SEC Rule 151A, File S7-14-08.