From: David N. Chick
I have been a NASD Principal for over 27 years and prior to that was an NASD examiner.
I have been providing my clients with both fixed and variable annuity products for 27 years and we have never experienced any problems with this particular investment choice. It is a conservative, well through out , financial product with both contact guarantees and income tax deferrral benefits. The rule you are considering will equate this VA with a number of risky investment products, i.e. options, currency warrants, etc. Your proposed new stricter suitability standards are totally biased and show a perceived lack of understanding of financial risk and suitability.
The current suitability standards for VA and other financial products are more than adequate to protect the investing public. If a SEC or NASD registered individual is not matching the client to their risk profile and if the product is not suitable for the investor, existing rules and regulations already cover that particular situation. If there is a problem, then enforce the current rules. There is no need to put more rules into effect if you are not already enforcing the existing reams of rules. It does not matter how many new suitability rules you heap on brokers and registered representatives, because those reps that care about their clients will continue to work in the best interests of their clients. Those that don't care should have the NASD or SEC regulators enforce the existing suitability standards.
This proposal does nothing to help the investor, it only continues to increase the onslaught of accumulating confusing paperwork!
I am against this new rule and I am in favor of existing suitability standards that are enforced.
David N. Chick,