November 3, 2008
The SEC#8217s draft regulation (rule 151A) adds an unnecessary layer of securities regulation to this insurance product. Rule 151A would turn most FIA products#8212as well as some
non-indexed fixed annuities#8212into securities. This will have far-reaching consequences by disrupting the manner in which these products are sold today. Thus, causing confusion
over the differences between insurance versus securities and providing little additional consumer protection at tremendous cost to companies, agents and ultimately clients.
An indexed annuity is not a security and should be treated as an insurance product.
Thank You,
Russell