July 2, 2008
This is a response in opposition to SEC Rule S7-14-08
I am a financial advisor and have been securities and insurance licensed for over 10 years. I currently can provide a wide variety of products to my clients, including securitites, cds, fixed annuities and index annuities.
As a financial advisor, I am not only supervised by a General Agency, but also I am mandated by my current broker dealer to disclose to compliance all index annuity recommendations to clients. Therefore, supervision of sales is very adequate and comprehensive. Yet, currently I have the flexibility of providing different Index annuity products with the support of various Annuity general agents. I find such support invaluable to my clients and to my practice.
Additionally, clients are able in many ocassions to save money on annual IRA or brokerage account fees by placing their purchases directly with an annuity company, rather than adding a level of superfluous administration.
Regarding consumer safety, the fact that there is a higher number of consumer complaints of variable annuities (which are a securities supervised product)versus index annuities (according to the NAIC)disproves the theory that making index annuities a security would improve consumer protection.
Finally, indexed annuities are a valuable tool when used properly, there are many insurance agents that have a strong relationshion with their clients and may be able to provide better service than alternative sources.
I thank you for your invaluable attention and thoughtful consideration
Regards,
David J Rosales