September 3, 2008
Both the design sales of annuities are highly regulated by state ins. dept's. as are the companies who manufacture and sell them. State ins. regulations cover, among other things, suitability of ins. agent recommendations re: annuities, annuity disclosure advertising, agent licensing training, unfair trade practices including misrepresentation of product terms conditions, and enforcement actions penalties for noncompliance with sales practice requirements. In addition, guaranteed minimum values for annuities are regulated through the Standard Nonforfeiture Law and are applicable to all fixed annuities. The securities regulation will add little benefit to consumer protection. Many,if not all, major indexed annuity carriers conduct suitability reviews of all sales in all states. Suitability reviews required of broker under FINRA rules would not add any meaningful protections over above whar is already being done. I oppose the proposed rule 151A., which could greatly impact my livelihood business as a licensed independent insurance agent. Sincerely, Michael D. Best