September 2, 2008
I am a licensed insurance agent. Please withdraw SEC Rule 151A. The securities regulaton will add little benefit to consumer protection. Many states have already adopted the NAIC Annuity Disclosure Model Regulation and most, if not all, of the major index annuity carriers have mandated the use of a disclosure statement or certificate describing all important terms and conditions of the annuity contract, including prominent disclosure of surrender charges. Many, if not all, major indexed annuity carriers conduct suitability reviews of all sales in all states. Suitability reviews required of brokers under FINRA rules would not add any meaningful protections over and above what is already being done.
Please allow the insurance companies adequate time to comment to ensure adequate analysis of the proposed rule. Thanks in advance for your consideration for withdrawing the SEC Rule 151A.