August 28, 2008
Florence Harmon
Acting Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609
Florence Harmon:
I am a licensed insurance professional. I am writing to you because I do not support the adoption of proposed Rule 151A, which would classify most indexed annuities as securities. I urge you to withdraw the proposal.
In my opinion indexed annuities should continue to be treated as insurance products, and the state insurance regulatory structure is the appropriate means for addressing the concerns raised by the SEC. The professional organization I belong to, the National Association of Insurance and Financial Advisors, is committed to working with the NAIC and state insurance commissioners towards the goal of having every state adopt and vigorously enforce the NAIC's model regulations on annuity suitability and disclosure. I also support NAIFA's recommendation that a state regulatory body be designated to develop standards for indexed annuity product design so that inappropriate indexed annuity products would be prevented from reaching the marketplace.
I urge the SEC to withdraw the proposed rule.
Thank you for your consideration of my views on this matter.
Sincerely,
Queen Reed