I am a licensed insurance professional and variable product salesperson. I would like to add my concerns regarding the suitability standard and principal review requirements pertaining to the sale of variable annuities contained in NASD proposed Rule 2821. From all indications, it appears the latest amendments do not materially add to the strengthening of the arguments articulated in the previous version.
While I wholeheartedly support the enforcement of any regulations to discourage those who engage in misleading or inappropriate sales actitivities of this or any security product, I respectfully urge the SEC not to support this proposal. The prospect of additional parties attempting to analyze the recommendations of professional advisors--in most instances without benefit of first-hand knowledge of material insights regarding a client's individual circumstances--holds the real possibility of underminding the advisor's credibility with that client. In my estimation, this does a great disservice to our clients!