I am a licensed insurance professional, (CLU, ChFC) and variable product salesperson with nearly 40 years of experience. I am a designated registered principal of a b/d branch office and have a series 7 securities license.
The proposed rule's requirements are redundant and will provide no additional protection to consumers. I urge the SEC to disapprove the proposal.
People who engage in misleading sales practices should be aggressively prosecuted. However, unsuitable variable annuity sales made up less than .50 percent of the NASD's disciplinary actions over the last five years, and complaints about mutual funds and individual securities far outnumber those concerning variable annuities.
Proposed Rule 2821 duplicates current supervision and suitability requirements that are already in place. NASD rules (including Rule 2310) already contain suitability requirements that apply to all sales of securities, including variable annuities.
Regulators should enforce the existing suitability rule rather than adopting a new rule.
I urge the SEC to disapprove NASD proposed Rule 2821.
Thank you for your consideration of my views on this matter.