October 21, 2008
While your offices are very aware that fixed annuity products fall under the definition of an insurance product and can in no way be classified under the definition of a security, I can only conclude that Rule 151A is, among other factors, an effort to obtain more revenue,regulation and control for NASD.
For the first time, as professionals, we can eliminate the downside for our clients without all the regulatory crap that securities require. And, we can do so with clear conscience, explaining the benefits of our products, through thorough, personal suitablility analysis with each client.
Please leave fixed annuities alone and allow the insurance companies and honest agents to serve their clients in the proper way. We know what our ethical responsibilities are.
Thank you.