November 17, 2008
To SEC,
After 24 years in the insurance/investment industry I could write a novel as to why there is absolutely no justification for labeling FIA's as securities. The points made by Allianz, Aviva, etc., in their responses are simply irrefutable and I will not recount them here. Suffice is to say, if the last few months do not convince the powers that be of the need for MORE principal protected products, and more agents to place them, I do not know what would. Obviously this ruling would cut both the number of agents and those types of products severely and the public would be the ones who suffer. The industry has already bent over backwards improving suitability to the point where it is difficult to even place a case and going even further would be gross overkill. I believe money and efforts would be much more wisely spent cleaning up the mess on Wall Street, where people can actully LOSE much of their life savings, than going after agents and products that promote safety of assets. This entire idea simply makes no sense and is entirely without merit and should be dropped immediately.
Sincerely,
Al Whitehead