July 17, 2008
I oppose Rule 151A for the following reasons.
1. This will decrease compition and reduce the number of agents marketing FIA's to consumers. There are more non registered agents than registered agents.
2. FIA's have been ruled in court not to be security's. and thus fall outside the perview of the SEC..
3. The compensation for this product over time is less than that charged by an investment advisor.
4.This product is an annuity and is purchased by consumers for the same reasons they would purchase a CD, or regular annuity's for the guarnantees of income and fixed returns.
5.Purchesers of annuitys are looking for less risk and volatility than security based products.
6. State mandated sales practices and disclosure requirements often exceed federal requirements, plus if the consumer has a complaint their state insurance department is much more likely to address thier conerns in a more timely manner than a federal burocracy. In MD notice's of violations are puplished regularly, and shows the states active persuit of agents/consumers who do wrong.