October 20, 2008
Comments: Dear SEC,
I understand that you are considering naming indexed fixed annuities "securities." I will say clearly that I am FOR the decision. Three reasons:
First, The products are fairly complicated for the clients. Often, the formula for the pledged return to the client limits their upside on the performance, while giving them all of the downside.
Second, they often have extremely long surrender periods. I believe many would not purchase them if they new how long the commitment is.
Third, naming them securities put them in an area where there will be "federally mandated disclosure and sales practice protections" as quoted from the body of the rule. It will force the sales person to both screen clients CAREFULLY and to disclose all aspects of it, before ever recommending one of these products. I advocate this fully.
Thank you
Sincerely,
Edward McCall