September 10, 2008
comments attached
fixed indexed annuities have all characteristics of fixed investments as Fixed annuities and CD's, and are not simular to securitiess as they have negative fluctuation eliminated.
Suitability guidelines are required by the insurance company and state insurance commission will review disputes without having to hire legal representation on the part of the client, further more you will find the complaint rate is lower than that with mutual funds.
Costs and competition will also be affected--client must have brokerage account to purchase FIA under proposal and additional costs of additional administration will produce less value to the consumer.
Consumer protection is not the issue, its the securities
dealers seeking to control sales and add additional revenues.
Legal issues-- Malone vs Addison found that FIA was not a security and negative impact on small agencies in the industry violates the 1996 Small Business Fainess Act