As a manager, trainer and Registered Principal of a major life insurance company office, I am writing to you concerning the suitability standard and principal review requirements pertaining to the sale of variable annuities contained in NASD proposed Rule 2821. Although the latest NASD proposal includes several amendments made to earlier versions of the proposal, the proposed rule's requirements are redundant, unnecessary, will provide no meaningful additional protection to consumers and will adversely impact my business. I urge the SEC to disapprove the proposal.
Our agents and Registered Representatives are subject to several levels of compliance and suitability on both the local general office level, all the way up to Home Office. They are thoroughly trained on all suitablilty standard and guidelines. In addition, the training and review are reinforced throughout the year.
The NASD proposal is a solution in search of a problem that could ultimately harm consumers by making these products less available to people who could benefit from them. For these reasons, I urge the SEC to disapprove NASD proposed Rule 2821. Thank you for your consideration of my views on this matter.