November 17, 2008
As a financial planner with over 37 years in the financial services business, I fully support the Commission's proposed rule on Index Annuities. The need for Federal oversight is significant as non securities registered sales people want to hide behind insurance regulation only even though they pitch the product as "a way to invest in the stock market without risk". For those that are securities registered, their broker/dealer has insisted for many years that this product is to be treated as a security. Common sense says it is. At a minimum, it is definitely a hybrid and in this age of transparency it is important that the public have all possible eyes watching. This proposed rule will help instill the investor confidence that is so desperately needed. While the product is complicated, with a thorough explanation and under the right set of circumstances, it is a product that works. Unfortunately, it is often not presented in a fair/competent manner. Please do not succumb to the insurance industry or the states by rescinding this proposed rule.
Thank you for your time and attention to this matter.
Sincerely, V. Raymond Ferrara, President and CEO
ProVise Management Group, LLC