July 24, 2008
THE SEC's draft regulation Rule 151A adds an unnecessary layer of securities regulation to this INSURANCE product. It is not a security. It has down side protection against loss. There are no dividends or capital gains like pure security products. There is also an insurance element payable at death. This rule would turn all annuities eventually to security products. Thus subjecting them to unnecessary security regulation and treatment. This will have far reaching consequences by disrupting the way in which these products are sold today. It will cause confusion over the differences between insurance versus securities, and ultimately providing little additional consumer protection at tremedous cost to companies, agents and ultimately consumers. A Cadillac is not a Volkswagon. A fixed indexed annuity is not a security, nor should it be treated that way. Protect the consumer more- YES absolutely. Changing a FIA to a security will not do that at all.