August 5, 2008
I believe that regulating Index Annuities as a security is misguided at best and probably disasterous in reality. It is the most freindly product for our older population for a myriad of reasons that I'm sure you have seen outlined many times. This decision if carried out will leave people with two basic choices. The Bank, with little earnings and taxation of the earnings which can increase social security taxation or Variable investments which puts them at risk.
Indexed products came about to fill a void financially for comsumers and have performed exactly as expected while ending risk.
If these products become regulated as securites, brokers will bury them and people will be denied an avenue that they have shown they really wanted.
Besides all of that they are not a risk product. They guarantee protection in many ways and allow consumers access to benefits not avalible in other products such as long term care benefits that health may prohibit them from accessing with other products.
This change would do a grave injustice to the people you are supposed to protect. Let the states continue to regulate these products as insurance products which they are.