October 17, 2008
I would like to express my concern of the proposed SEC Ruling 151. I have been an independent life/health insurance agent for 21 years and I have always prided myself in providing my clients with what I feel are good, safe, quality products.
I include FIA's in my business and have researched companies that I believe to have the best product for my clients. As in any product, an FIA can vary according to which company is selling the policy. I firmly believe that the several companies of which I use to help my clients prepare a solid portfolio are leaders in this market. One of my selling points is that if placed in the proper FIA and if the client abides by the contract that I am explaining, a client will not suffer a loss of principle or credited interest if there is a fall in the market.
I honestly do not understand how an FIA can be classified as a Security. In a Security product the client feels the brunt of the loss, not the company. The opposite is true for an FIA.
My husband is a federal employee and contributes to the TSP. Although he has continued to contribute every pay period, his TSP portfolio has suffered a $30,000 loss from this time last year. That TSP fund is NOT an FIA, but a Security product.
Please reconsider this ruling and do not place a product that has no simularities to a Security product in that classification.
Sincerely,
Sherry G Wood