From: Peter D. Fischel, CLU
I have been a licensed life insurance agent for over 35 years, and a Registered Rep. for 30 years. In that time I have never had a complaint filed against me.
Suitability has always been front and center for the vast majority of Registered Rep's, and I and this vast majority believe that anyone who engages in deceptive or misleading sales practices should be prosecuted to the full extent of the law.
My reason for writing to you is that I am concerned that the NASD is in the process of ruining the annuity business by an absolute "over-kill" in regulations! This relates to ALL classes of annuities, which include annuities over which NASD has no legal jurisdiction.
In particular, one of the latest ventures for the NASD is their proposed Rule 2821. It is clear that the NASD operates with the notion that they and B/D Principals have more knowledge regarding a given client than a long-time experienced rep such as myself does. There are ample rules and regulations, and supervision directives on the books. The NASD should enforce these rules, etc., instead of promulgating additional and redundant ones.
Furthermore, making it even more onerous for honest, fair-dealing rep's could make these products less available for those consumers who could most benefit from them, because most rep's deeply resent B/B "second-guessing", and thousands of rep's have and are giving up their securities registrations.
For all the forgoing reasons I urge the SEC to disapprove NASD proposed Rule 2821!
Peter D. Fischel, CLU
p.s.- I am 71 years old, and will probably work a few more years. So, my comments are NOT only for myself, but mainly for my younger colleagues.