August 11, 2008
I work in the insurance industry as an annuity sales consultant and the vibrancy of this business is my livelihood. If passed, Proposed Rule 151A would devastate the insurance industry and put thousands, if not tens of thousands, of people out of work. With the recent crises in the mortgage and credit industries and a weak economy, does the SEC really want to invite a move that might cause the same kind of upheaval in yet another industry?
The proposed regulation is duplicative and over-reaching. The NAIC has passed and enforced multiple new regulations to ensure ethical sales practices, product education and ongoing monitoring of sales to seniors. Not every industry is perfect, however, great strides have been taken to curb practices of a few bad apples that have ruined the bunch. We are an industry perfectly capable of policing itself.
Proposed Rule 151A is ill-conceived and demonstrates a disturbing disregard for previous legislation that exempted annuities from securities law. These products will not return less than a minimum guarantee to a client: ever. To charge otherwise is demonstrate that the SEC does not understand how these products work so why should the SEC regulate them? That would invite more confusion and misrepresentation of products that are safe, guaranteed and offer income that a client can never outlive. Or worse yet, would make obsolete products that are a benefit to the public that buys them.
Please consider how devastating passing Proposed Rule 151A would be. To ravage an industry in an already weak economy on principles that are shaky at best, is not in the best interest of consumers, the United States economy, the insurance industry nor the SEC.
Thank you for your time and consideration.
Sincerely,
Jaime Nipple