November 14, 2008
I am writing in support of the proposed SEC oversight of equity indexed annuity products. I am an investment officer in a mid-sized trust company and spend about a third of my time face-to-face with clients and prospects. During my 20 year investment career, I have worked both in an insurance company where we introduced an EIA product and now more directly with the consumers to whom the products are marketed.
These are complex products being sold to mostly unsophisticated buyers. The purchasers frequently don't understand what they are purchasing (terms, risks, surrender charges, etc.) either because they don't have sufficient background to truly understand or because they are actively being misled by abusive sales practices. I see the proposed rule as a rational approach to balancing the need to protect consumers against an open and innovative market for financial products.
Thank you for considering my viewpoint.
Mike
Michael R. Hochholzer, CFA
Senior Vice President & Portfolio Manager
Associated Bank