September 10, 2008
To the SEC;
I am writing to strongly oppose the proposed SEC rule 151A
I have been in the financial services industry since 1964. I have a CA Insurance Lic# OE17363. I also have a series 6,63 & 24 securities lic. I have been under the supervision of the SEC on security issues for many years, and have managed others in the security business as well. I have also been a General Agent in the insurance industry and have managed producers in the insurance arena as well.
They are clearly seperate markets, and need to be regulated differently. It has been proven over and over again that Flexiable Indexed Annuities are not a securities. Yet the SEC continues to try and regulate them. That is clearly overstepping the authority of the SEC.
The security industry needs to clean up it's own back yard before trying to step over and regulate the insurance industry. It only requires a quick look at the complaint files to see that, FAR more, complaints are against the securities side than the insurance side. and fewer still against Flexiable annuities. Most of the complaints are against Variable annuities; already regulated by the SEC..
To even mentioned the "Dateline" show in a proposed regulation proposal, shows how little the SEC knows about the FIA industry.
Let the insurance industry police it's own products and field force, and let the SEC try and do a better job of policeing their own securities industry.
In closing, I again wish to strongly oppose SEC proposed ruling 151-A
Alan Van Portfliet
Business Consultant
Asset Marketing Systems