August 29, 2008
To whom it may concern,
I strongly feel that FIA are fixed annuities and not variable. They play an extremely important role for my clients. I have over 200 clients that I serve in PA, OH, NC. I also feel a change from what we have nowwill cause a negative economic impact well in excess of $100 million to small agencies within insurance industry. This violates the Small Business Regulatory Enforcement Fairness Act of 1996. This efffects independent agents like myself, which whole livelihood is based on insurance products and guarantees that I can provide to my clients. I have produced over 15 million dollars in indexed annuity premium over the last 8 years, and do not have one complaint from clients and/or thier beneficiaries. The indexed annuity is an essential tool for me to use in my insurance firm. This rule will reduce competition and harm consumers that do not want to be involved with brokerage houses. This rule, if passed to turn a FIA into a security, would be detrimental to the independent agent and his/hers thousands of clients that depend on their service. Everyone of my clients understands what a FIA is before, during, and after solictation and they understand WHY it is not a security.
Thank you.