I am a financial representative with Northwestern Mutual and have been working in this capacity for 14 years. I am licensed to sell insurance as well as variable products. I am writing regarding the NASD proposed Rule 2821.
I strongly believe that those who practice misleading sales tactics should be prosecuted and subject to the appropriate penalties under the law. However, creating more laws and rules is not going to take care of the problem. A lack of appropriate enforcement of the laws already in force seems to be the major problem. Proposed Rule 2821 is redundant in its current supervision and suitability requirements.
I believe that passing Rule 2821 could ultimately harm my business. My clients would be questioning my advice and worry about the products because a principal would be required to review everything. This rule seems to have a bias against the products and treats the financial representative as if he is insufficiently trained.
In summary, I believe that Rule 2821 is an unnecessary and ultimately detrimental rule for those in the insurance and variable product industry. I urge the SEC to disapprove NASD proposed Rule 2821. Thank you for your consideration of my views.