September 8, 2008
To SEC: Rule 151A affects many people and their livelihods, thus it needs more time for study and adequate comment. The comment period should be extended by 90 - 180 days. This is critical to good rulemaking and public input.
The proposed rules would have too many negative effects, including creating an unnecessary & unwise extra layer of regulation. The State Insurance Departments & NAIC now adequately regulate fixed annuity and insurance business. They and we already have detailed disclosure, privacy, and suitablity requirements and paperwork. There are few if any compalints in this area (per NAIC Customer Information Source report shows only abt 0.12% or only abt one tenth of one percent complaints), leaving 99.88% satisfied, or at least not wanting to complain. This is hardly the stuff of of a business crying for regulation. Does the SEC's own regulated business have such a sterling record?
The SEC does & should properly regulate variable products including variable annuities. They should also regulate the areas of hedge funds & subprime loans which are in great need of oversight. But fixed index annuities are already sufficeintly regulated on the state level, and SEC rules in this area would be confusing & deterimental to business and consumers alike.
Sincerely,
FPM
Francisco P Maribona,
25 yr. General Agent