July 15, 2006
Dear Sirs and Madams:
My review of the above referenced file, specifically the proposed changes to the variable annuity sales practices and supervisory standards, indicate that the current supervisory and variable annuity sales practice rules are adequate to ensure our clients are given the proper tools to make informed investment decisions.
Variable annuities offer a very unique and important function with today's aging population. Not only do they guarantee a minimum death benefit, they also offer living benefit income guarantees.
There will always be unprofessional and unethical representatives in any business and I believe that the NASD and SEC already have the proper rules and regulations in place to police these few "bad apples" in our industry.
Passing of this rule would only serve to penalize the rest of our ethical and moral community because of these few unethical and immoral reps. My clients are currently required to sign in approximately ten places for a variable annuity contract application. Additional disclosures would be onerous and ineffective.
Most firms have developed a checklist of important points relating to variable annuity sales practices which are reviewed with the potential client. These checklists are more than adequate in properly informing clients of both the advantages and disadvantages of variable annuities.
In seeking to require extensive investment experience as a prequalification for clients, I see this as a huge injustice to clients who need the possible growth of principal and who are currently invested in fixed products. Informing clients of how inflation will increase the amount of income they will need at retirement is essential to their ability to maintain purchasing power of their dollar during retirement years.
As a principal reviewing these investments, a requirement to review each transaction within two days has pitfalls. A limited review period is must have been arbitrarily created and serves no useful purpose. Imposing a short review period for principals only serves to undermine their ability to perform an accurate and thorough review.
Related to the value of death benefits, ask any widow whose husband's assets were invested in a variable annuity whether or not the death benefit was worth the additional cost during the years of 2000, 2001 and 2002, when markets retreated. What other porduct is available that provides the potential for growth plus assures clients of no loss of lifetime income based on investments in variable annuities?
No doubt, fees are higher than mutual funds, but what mutual fund offers a death benefit or a lifetime income benefit?
I ask you not to make changes to the current checks and balances already in place regarding variable annuities sales and supervision practices.
Thank you for taking the time to review my comments.
"An Investment Advisor Representative offering securities and Investment Advisory Services through Transamerica Financial Advisors, Inc. A Registered Broker/Dealer and Investment Advisor. OSJ 0273, 368 North Kingshighway, Sikeston, MO 63801, 573-471-3339, Member NASD & SIPC."
This e-mail and any attachments are intended only for the individual or company to which it is addressed and may contain information which is privileged, confidential and prohibited from disclosure or unauthorized use under applicable law. If you are not the intended recipient of this e-mail, you are hereby notified that any use, dissemination, or copying of this e-mail or the information contained in this e-mail is strictly prohibited by the sender. If you have received this transmission in error, please return the material received to the sender and delete all copies from your system. Recipients should be aware that all emails exchanged with the sender are automatically archived and may be accessed at any time by duly authorized persons and may be produced to other parties, including public authorities, in compliance with applicable laws.