September 8, 2008
I am opposed to SEC Proposed Rule 151A.
Fixed Indexed Annuities are well-designed insurance products that give consumers guarantees, principal protection, flexibility, and tax-deferral. These products are clearly not securities by definition. State insurance departments currently regulate the sale of FIAs. These regulators are continuing to improve the oversight of FIAs sales through their work with insurance companies, and the NAIC. The SEC is now saying it is the SEC's position that the current regulatory process is no longer valid. The SEC is proposing to redefine the product as a security, and step in and provide oversight. This action I firmly oppose.