July 18, 2008
Comments:
I have been in the financial services business since 1981 and have been serving my clients and independent producers ever since it is my strong opinion that " fixed indexed annuities " are not securities as prior rulings have dictated. There are many consumers who enjoy the opportunity to earn an interest credit that could be potentially higher than they might otherwise receive in the stated interest category While knowing that they will never suffer a loss, and if the credits or lack thereof will still provide a minimum guarantee based on contract terms. This product serves quite nicely the savers that deposit monies in these contracts.
I see know benefit to increasing costs by requiring registration of these products, and in fact see great harm to those we serve Whilst, there is a small percentage of agents who sell these products in an iappropriate manner the overwhelming majority do not You make reference to the Dateline episode that was shocking in that they profiled known individuals who do not have there clients interests at heart You might consider the inappropriate sales tactics of many registered reps in the sale of variable contracts to individuals that lack understanding and have risk tolerances far below the allocation of most accounts
In conclusion it is baffling to me that now we have a ruling that is in direct conflict with the standard set by your own agency when these products were introduced back in the mid nineties The public and agents should be able to rely on your consistency so that they can continue to serve the needs of there clients.