August 7, 2008
Although an insurance product is used as the overlay delivery vehicle, at least part of the underlying dollars are invested in investment products that effectively are mutual funds. These "mutual funds" must be understood in the context of a client's entire investment portofolio, not simply by considering only their use in the annuity product. Insurance agents who are not licensed to sell securities do not have at least a minimal understanding of how these "mutual funds" can be used in an entire portfolio context. Securities licensing requires at least some basic understanding of how securities relate to each other.
Therefore, I favor licensing under the SEC provisions.