August 27, 2008
PLEASE WITHDRAW THIS PROPOSED RULE FOR THE FOLLOWING REASINGS:
A. ENACTMENT OF THIS RULE WILL JUST ADD ANOTHER LAYER OF REGULATORS TO THE DISTRIBUTION SYSTEM FOR "INSURANCE PRODUCTS" THAT DOES NOTHING TO PROTECT THE CONSUMER!
B. I BELIEVE THE CURRENT SYSTEM HAS BUILT IN SAFEGAURDS FOR THE CONSUMER.
C. REQUIRING A SECURITY DEALERS LICENSE ADDS AN ENORMOUS EXPENSE FOR THE LIFE-HEALTH-ANNUITY SALES AGENT.
D. IT ALSO LOCKS UP A PRODUCT TO A GROUP THAT HAS COMPETETIVE PRODUCTS THAT THE NASD LICENSED AGENT WOULD USE IN PLACE OF THE INDEXED ANNUITY PRODUCT REMOVING IT FROM AVAILABILITY TO THE GENERAL PUBLIC.
MY NAME IS: LEE M GOERES, AN INSURANCE AGENT FOR 30 YEARS, PAST STATE PRESIDENT OF NAIFA, "NATIONAL ASSOCIATION OF INSURANCE AND FINANCIAL ADVISORS", PREVIOUSLY NASD, ALSO CPA, NOT CURRRENTLY PRACTICING.