November 18, 2008
To Whom May Read This Commentary
My name is George M. Villa. I am an insurance licensed agent ( life and health) domiciled in Illinois. I have several non-resident states. I am also an investment advisor representative and hold in addition a series 6 & 63. I am a member of NAFA, NAIFA, FPA, MDRT as well as other organizations. I oppose the proposed rule.
I have been in this industry since 1998. Having seen many changes during the decade of working with clients. This proposed change, is in my humble opinion, has NOTHING to do with what is good, proper, nor suitable for american public, especially "senior" or "retirees". Rather it is a move simply for power and revenue of the securities industry and those whom regulate it.
NONE of my clients, with assets in any Fixed Index Annuity (referred to by those without proper education and training as EIAs) has experienced a penny lost due to index volatility....NONE Simply stated, why in the world would anyone, truly with american retirement safety, preservation, and or protection advise their loved ones to risk their life savings in the securities market. HONESTLY.
The securities industry, has made shambles again of life savings, with the "your all in" philosophy and "it'll come back, just hang in there". All the while top to bottom collecting fees, commission and charges.
Like little Nero's fiddling while Rome burns. It is immoral what has been thrust upon them by the irresponsible behavior of such "advisors, brokers et al" of the securities industry. AND NOW they seek to gain the power to regulate one of the only products, that has done exactly what it set out to do. Offer the potential for market indexed credited products without the opportunity of market index loss.
People, my clients stop me at the grocery store, like Dave J. did and thank me for keeping their life savings safe..and stating, sure glad that we are not losing like so many others are..thank you. I have had at least three couples approach me in resturants to thank me for the peace of mind, security, and safety the products have provided. Too many to mention have commented that they wish that they had placed more in the fixed index annuity. Many others are planning to place more assets into the products.
This proposed 151A. is not supported by any empirical eveidence to support the Commissionars claim that widespread abuses in selling the product exist. Funny thing is that in the rhetoric even a tv show "special undercover" was offered as support. Many of our client watched that event, and called unsolicitated and said how blatantly biased that show was.j Are there instances of complaints? Yes, however, fixed index annuity complaints represent .1% of all complaints filed with state insurance departments. All members of the industry deplore fraudulent, misleading or abusive sales practices. The regulations and NAIC suitibility model as well as education and insurance company compliance/suitabiltiy is direct saleforce connected. The public is protected currently.
This proposed regualtion in my humble opinion is about power, fees, revenue not about public interest.
Now, insurance agents do not have to be securities registered, IF APPROVED fees for license, fees for test, fees for ongoing test, fees for selling product, fees for suppervision, brokerage house commissions
Now, clients are not charged to their deposit commission, IF APPROVED fees for product purchase, fees for commissions, fees for administration, fees for account choices are likely
Now, clients have access to valuable desired choice, IF APPROVED the public would be restricted Now, FIXED INDEXED ANNUITIES are NOT SECURITIES. PERIOD There is and should be NO IF APPROVED Please Honestly look at the world. Please Honestly look at the products sold by the securities industry. Please Honestly consider the fact that during ALL market losses in products under the watchful eye of the securities industry.....with TRILLIONS OF LOSSES>>>oh, and by the way continuing to CHARGE FEE AND EXPENSES WHILE LOSING THE PUBLICS MONEY....
The lowly Fixed Index Annuity, has done honestly exactly what is was intended to do, give a fair return, protect the princple, and not lose. I specialize in the"second half of the game"; where risk is considered any place where one can lose princple and or credited interest. The fixed index annuity product is a tool. It has a purpose. It is not right for everyone. However, it is a very good tool. That currently is properly regulated. It has been found by court decision that it is not a security; and i concur I respect the industry. I do have clients with money at risk in the market. HOWEVER, with all due respect. Leave this product to the states who already have extensive regulation.
Thank you
Respectfully
George M Villa