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Nancy M. Morris
Dear Secretary Morris, I am writing you in opposition to the proposed rule changes in regard to the Variable Annuity Sales Practice & Supervisory Standards Rule (NASD Rule 2821) I have been securities licensed since 1993 and have seen a tremendous amount of increased compliance and suitability oversight in the sale of variable annuities. I believe that the current level of supervision and oversight is adequate to protect the consumer from the inappropriate variable annuity sale. I personally only recommend a variable annuity when the benefits to the consumer clearly are in line with the increased fees over that of a mutual fund or any other investment. In addition the forms we use provide full disclosure of all fees and chargers so that the consumer can determine if the living benefits, or for that matter the death benefit, are in line with these additional charges. Currently the Broker/Dealer I clear through does require both review and annual training with regard to variable annuities with an emphasis on suitability. I believe that the current training levels are appropriate for those of us that present a variable annuity as the answer to an individual investor's goals. I also don't believe that only the experienced investor should be able to consider a variable annuity. The great majority of the time that will be the only person that would consider this type of investment. However to "handcuff" someone because they had not ever considered such an investment is just not fair or just in every case if that becomes the rule. I am not in management and I am not a supervisor but I can see that additional "rules" will not defer those very few "bad apples" from misusing the variable annuity sale. I truly believe that the proposed rule changes would actually do more harm than good with many unintended consequences to the consumer.
Gary M. Gillan PS I have personally not sold a variable annuity this year primarially because the "situation" has not been right. If the "situation" is right I do not believe that the proposed rule changes will be of benefit to the consumer...which I belive should be the ultimate goal!
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