November 17, 2008
Dear SEC,
Please note my professional opinion that index equity annuities should be regulated by FINRA or some federal regulatory agency since the current sales practices I have seen as a CPA in private practice have been horrible... where in insurance licensed professionals are marketing a product that is tied to a security. For example, an equity indexed annuity being tied to the S&P index, yet the professional selling the program is not security licensed. Moreover, the states have done a horrible job in regulating insurance agents making above normal commissions 4 to 5 times of what is traditional on annuity products that take 15 to 20 years to become liquid to mostly senior citizens that thought they bought a CD... The insurance agents have no compliance officer at the broker dealer level looking at what they are doing... and to protect seniors... things should change... where as insurance agents that want to market to seniors these products should get the appropriate security license because the product is tied to a security and hired by a broker dealer that supervises their sales practices like the scrutiny other advisors that deal with securities have to professionally deal with and stay square with the rules...
Sincerely,
Daniel C. Zebrowski, CPA, PFS