November 13, 2008
I am opposed to unnecessary oversight. In this case, I think the rule to bring EIA programs under the jurisdiction of the securities industry IS necessary.
I manage a very small broker/dealer in the Detroit Metro area. As manager I have several registered representatives that discuss their sales practices. Over the years I have heard most of them tell me how they sell and market EIAs. Every time I have listened to them describe EIAs I have been struck by the fact that their EIA description sounds like a security. They all tell me the EIA is an investment that can't loose and that participates in market gains.
These RRs are all veteran agents. Yet time and again their communication is such, that viewed objectively, would not satisfy the FINRA Safe Horbour rule in the sale of EIA products.
I had no choice but to take the EIA product line internal through a partnership with an annuity wholesale company.
The SEC initiative is based on good instincts and I support it.
In addition to my designations below, I am a member of the FPA, SFSP, and have been Life Insurance Licensed since 1990, Series 63, 7, 24 and 53
Mark Davis, CLU, CFS, RFG, ChFC
Registered Representative, Municipal Fund Securities Principal, Registered Principal President, Chief Compliance Officer, AML Officer, Haas Financial Products Incorporated Investment Adviser Representative, Vice President of Haas Financial Services