July 8, 2008
Dear Regulator,
I have just learned that the indexed products included under File Number S7-14-08 are being considered to be removed from the list of sellable products for the agents that are not securities licensed. I want to go on record as to opposing this duplicated action. The agents who have a securities license are to be the only ones that can sell this product. That is putting the rest of the agents like myself in an unlevel playing field….(There are thousands of us who have already received many hours of training in this field) I have sold this product for about 8 years. It is not a stock market product. I feel like the bulk of insurance agents can and do sell this product very competently. Many of the companies that market this product have pretty much made it fail safe even if one of the agents purposely tried to mislead either by design or ignorance. There are built in benchmarks to protect the customer from the unscrupulous agent. It is like any other life product that can be misrepresented if the agent really wanted to. We do have safeguards against this already…it is called an insurance commissioner and a complaint system that can put that agent out of business or at least suspend any financial activity as far as insurance sales immediately. You have the department who has a list of companies that that agent does business with who can stop any sale that is generated by that agent as well as the company..who most are regulating the agents as well. Please allow the current products to be marketed with a non securities license and vote no to the Index Product S7-14-08 regulation.
Thanks,
Mike Holmes