September 10, 2008
I am an Independent Elder Planning Insurance Agent/Broker.
I have been previously Securities Licensed but made a decision to Eliminate Risk for my Senior Clients. I have a
Business Degree, Professional Life Insurance and Annuity Cerifications, Life and Helath Ins. Licenses, and am curently the President of our Local Chapter of the National
Association of Insurance and Financial Advisors (NAIFA). Many of our Members are Securities Licensed. Yes, I have a vested interest in the SEC's proposed rule, 151A. I am very
much against duplicate regulation for Fixed Indexed
Annuities. State Insurance Depts. are presently regulating these financial products.
1st, a Fixed Indxed Annuity is a Fixed Annuity. As a Fixed Annuity, these products have Guarantee of Principle and have
Minimum Interest Rate Guarantees. The only addition is a contractual index to a Market Index, most often the S and P 500. The Owner of a Fixed Indexed Annuity is not invested in the Market, they only have a Contractual Index to the Market. The Life Insurance Company carries 100% of the Risk. How can a product that has no risk be a Security, and be regulated by the SEC? It is not a Security. As such, it should not be regulated by the SEC.
2nd, Life Insurance Companies have to be over 100% collaterized. This is currently the Law. In addition, all States have reinsurance guidlines with a % of Premiums going to pay for potential buy-outs, if a Life Insurer becomes insolvent. Banks by comparison are about 40% collaterized. Broker Dealers are less safe than Banks. There is no safer place for a person to put there "Safe" Money. When a Retiree makes their Qualifed Retirement Plan, Retirement Pay-out Choice, where does their Plan Assets
go (most with Assets in the Stock Market) for a Life Pay-out? It goes to a Life Insurance Company's Annuity.
Only Life Insurance Companies guarantee lifetime income streams. The SEC should regulate Risk based Securities, not Guranteed Fixed Indexed Annuities.
Who bailed out Banks and the Securities Industry after the Great Depression? The Life Insurance Industry. Please stay out of the Life Insurance and Fixed Annuity Business. Life
Insurance Companies, most Life Ins. Professionals, NAIFA, my Clients, and myself will in-fact fight your proposed rule, 151A, to the end. This is a promise you can bank on,
without risk.