From: Robert Jenkins
I am contacting you regarding the proposed suitability standard and principal review requirements from NASD proposed rule 2821. From what I have seen it is redundant and may require more time to duplicate paperwork that is already required.
From the statistics that I have seen variable annuity sales are less that 50% of the NASD’s disciplinary actions for the last five years and the complaints received about mutual funds and individual securities far outnumber the complaints towards Variable Annuities. If the NASD is in search of a problem solve the mutual fund complaints.
I would rather see better enforcement of the current regulations than new duplication ones. The suitability forms (and supervisor overview) I fill out for my broker dealer require the same information for either variable annuities or mutual funds to prove whether the product meets the needs of the consumer.
PS I would love to see better regulation of the equity indexed annuity market. Many of those selling have no securities licenses, do not understand the product and are promising market returns that the products cannot supply. I think that anyone selling an indexed product should have to have a security license and be regulated. I also think that the advertising should be better monitered.
Robert Jenkins LUTCF
Financial Services Professional
Registered Representative offering securities through NYLIFE Securities Inc. (member NASD/SIPC)