November 13, 2008
To Whom It May Concern:
I am a member of the Financial Planning Association and I support the proposed rule. I am a CERTIFIED FINANCIAL PLANNER with a fee-only Registered Investment Advisor. I have been in the industry for 7 years and have seen many damaging situations caused by commission based insurance and investment products. Protecting the consumer and providing transparency should be the primary goal of the SEC in this matter. In short, my arguments in favor of this rule are:
a. the rule is a reasonable and balanced approach to enhancing state enforcement efforts
b. the vulnerable aging population needs additional protection from aggressive sales agents
c. consumers are often mislead regarding the benefits of an indexed annuity
d. liquidity risks, surrender charges, and other suitability factors are not always clearly disclosed or understood
e. not all states have adopted suitability standards for annuity sales, nor do most insurance commissioners have adequate enforcement resources available
f. some agents misrepresent themselves as offering a single retirement solution when in fact retirement planning is generally a complex planning process
Matt Cook
---------------------------------- Matthew A. Cook, CFP® Financial Advisor Mercer Advisors