November 14, 2008
Dear SEC,
I am a CFP and the chapter president for FPA New Mexico.
I fully support the proposed rule.
I attended a seminar to seniors totally focused on Equity Indexed Annuities and hosted by a licensed New Mexico insurance agent. The presentation summary went like this - an EIA is the solution to all investment problems.
In my limited experience w EIAs, I find them to be extremely complex not only as a broker (Series 7, 63 and 65) but very difficult to explain to even a fairly savvy investor.
Please consider:
* the rule is a reasonable and balanced approach to enhancing state enforcement efforts
* the vulnerable aging population needs additional protection from aggressive sales agents
* consumers are often mislead regarding the benefits of an indexed annuity
* liquidity risks, surrender charges, and other suitability factors are not easily understood
* not all states have adopted suitability standards for annity sales, nor do most insurance commissioners have adequate enforcement resources available
* some agents misrepresent themselves as offering a single retirement solution when in fact retirement planning is generally a complex planning process
Sincerely,
Phil Messuri, MS, CFP
Financial Planner Association, New Mexico Chapter President
Financial Network, an ING Company