I have been licensed and selling variable annuities for 26 years and am writing in response to NASD proposed Rule 2821. Even with the amendments to this rule it is still redundent and will have a negative impact on my business while not adding any new safe guards for consumers. I urge the SEC to disapprove the proposal.
Anyone engaging in misleading sales practices should lose their license and be fined appropriately. There are laws currently in place that govern that. Rule 2821 duplicates current supervision and suitability requirements that apply to all sales of securities, including variable annuities. Since variable annuities accounted for less that 1/2 of 1 percent of the disciplinary actions over the last five years there is no reason to single out variable annuities for increased supervisory requirements. This is evidence of bias against one product versus another.
Sold for the right reason to the appropriate client Variable Annuities are a valuable tool. Assuming that the government using averages and assumptions is in a better position to decide what is best for my client's situation is irresponsible. Surely after gathering all the facts and discussing them with the client the client is in a better position to judge what is best for them.
Anne Graves, CLU, ChFC, REBC, RHU, LUTCF
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