Hello SEC: I am a licensed insurance professional and Registered Representative. I am requesting that the SEC disapprove NASD proposed Rule 2821.
Currently, I am filling out Variable Annuity (VA) Disclosure Forms with all VA sales. This is because the NASD and my Broker Dealer require me to do so. The proposed Rule 2821 is redundant because I am already going through disclosures with my clients.
I also believe that Variable Annuities are one of the few products that are going to allow retirees to keep up with inflation without putting their entire retirement portfolio at risk. It is my understanding that unsuitable variable annuity sales made up 0.50% of all the NASD discliplinary action over the last five years. I also understand that complaints about unsuitable stock and mutual fund recommendations far outweigh complaints against VA sales.
Please understand that I think the industry should aggressively pursue action against producers who are misleading client's into VA sales. However, I just do not believe that adding additional rules and forms is the answer. The rules we have in place now more than adequately allow you to take action against producers making inadequate, misleading or poor recommendations.
Again, please DISAPPROVE NASD Proposed Rule 2821. It will further complicate my business and others with more red tape. Ultimately, we are working for the client's financial welfare and additional rules will only hurt us that are doing the business the right way.