August 13, 2008
I am very pleased to see that suitability of FIA products for the senior market is the reason for this proposed legislation.
I am disheartened that this has come about as a result of commission driven sales practices by individual agents.
As a result of recent legislation in my home state, I have become registered as an Investement Advisor Representative allowing me to discuss securities with my clients. It has been very advantageous to my practice and believe it has enhanced my overall business model.
FIA Sales need not be regulated as a security product due to the fact the insurance company has the burden of "risk" not the individual. As with home, car and health insurance we transfer the risk to an insurer for protection of the unknown. If it can be proven that the insured bears "risk" then FIA's should become regulated as securities products.
The securites market has its place for those willing to take "risk" When the "risk" is eliminated and transferred, that by definition becomes insurance.
I feel that agents wanting to pursue the marketing of FIA products or discussing securities should have additional requirements "NOT THE PRODUCTS" themselves.
FIA's design left intact adhere to the definition of insurance, but the marketing and sales of these products is the real issue