August 11, 2008
I have been in the insurance business since 1987. In addition to an insurance license, I have a Series 6, 63, and 26. I strongly believe that fixed index annuities should not be classified as securities because there is no downside risk to the client. Unlike investing in a market related index or a variable product (which both contain market risk) the insurance company guarantees their money. The interest that is credited and the method used is clearly stated in the contract.
State insurance departments should have responsibility for regulating fixed insurance products that are licensed in their state. Please reconsider your proposal and instead work in conjunction with the insurance industry to ensure suitability standards are met. There is no reason to unnecessarily increase the costs involved in purchasing these products. Only the consumer suffers here.
Best regards,
Jean Casagrande, CSA
Streettalk Insurance Agency, LLC
2500 City West Blvd, Suite 300
Houston, TX 77042