August 28, 2008
Dear Sir/Madam:
I have been in the securities, financial planning, and insurance businesses for over 20 years. During that time, I have had occasion to use Indexed Annuities as well as other investment vehicles. It is very obvious to me that Index Annuities are very different "animals" than security products. Having these insurance investment vehicle regulated like mutual funds is a real stretch and I do not think the securities regulators know how to handle them.
I think additional study of this entire issue needs to take place. Index based products, both annuities and life insurance policies, are complex and each one is different. I think you take another look at proposed Rule 151A and reconsider having FINRA and the securities system monitor this method of handling fixed insurance products.
Thanks!
Brent Beverly