November 13, 2008
Dear Sir or Madam,
Oversight and regulation of index annuities should remain under the purview of the SEC. Retention of this oversight is strongly recommended. The proposed rule should be adopted.
I am a member of the Financial Planning Association and Society of Financial Service Professionals and a CFP(r) Certificant. My practice is that of a fee-based financial planner who often recommends a wide range of investment and insurance products appropriate for my clients.
Indexed annuities can be both appropriate and valuable to clients in the financial planning environment but remain complex and less than transparent to even sophisticated clients. The rule is reasonable in complementing the efforts of the states. However, I am aware that my principal state, Virginia, lacks adequate resources for enforcement of this product which can be easy mis-understood by the client and their famlies as to the internal features. Due to the complexity of the product, its benefits and performance can be easily either misrepresented or misunderstood -- both of which puts the client at risk.
To reduce the SEC's role in the oversight of these products is to put a vulnerable client base at substantial risk.
Respectfully,
Mark O. Flaherty, CFP(r)
Financial Advisor