November 17, 2008
Dear SEC Staff:
I am NAPFA registered fee-only financial advisor writing in support of the proposed rule that would allow for SEC oversight of indexed annuity sales in addition to state oversight by insurance commissioners. The liquidity risks, surrender charges, and other suitability factors for equity-indexed annuities, in my experience, are not well disclosed or understood by either the consumer or even by the sales agents. As a result, the consumer is seeing only the “sizzle” in the advertising without being able to have a clear view of the risks—or the costs. These are innovative products that need modern, interdisciplinary regulation. Allowing SEC oversight in addition to state oversight by insurance commissioners would be a major improvement in consumer protection. Please add my vote in favor of the proposed rule. Sincerely yours, Paula H. Hogan.
Paula H. Hogan, CFP, CFA
Hogan Financial Management, LLC