July 25, 2008
I respectfully disagree with the proposed rule for the following reasons:
1. Equity indexed annuities are not SECURITIES by any stretch of imagination. It's only the interest crediting method which is tied to the performance of the index. At no time the client's principal money is at risk due to market fluctuations.
2. It's is true that there are surrender penalties, which is always disclosed to the client up front. If surrender charges were the consideration behind this ruling, then all Certificates of Deposit should be subject to this rule as the clients loose money should they decide to surrender the CD ahead of schedule.