RILAs are inherently misleading products. They misleading about performance by using a price return index. This is even worse when performance is measured against an ETF. You are not getting the performance of the index, you are getting the index performance after a large haircut. They misleading by stating there are no ongoing g fees. Just because a fee is hard to pricely identify does not mean there is no fee. If funds and variable annuities have fees, these products certainly have fees. Otherwise they are suggesting that if you hold past the surrender charge period it is free. That is simply not true. Insurers can change the rates at will. That is not right. They should pay market rates less.a specified amount. Your proposal needs to do more to protect investors.