I am a licensed insurance professional. I am licensed as a variable product salesperson. 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. I agree with The NASD proposal.
The latest NASD proposal will provide meaningful additional protection to consumers and will not adversely impact my business. In fact, it will create a positive result; protecting my prospects, my clients and assure them there are safeguards to protect the small investor.
I urge the SEC to approve the proposal.
I firmly believe people who engage in misleading sales practices should be aggressively prosecuted and subject to appropriate sanctions.
The NASD, however, has justified the need for the proposed rule.
The available data does support the NASD's claims that the level of sales problems in the variable annuity marketplace calls for the adoption of a new proposed rule.
Unsuitable variable annuity sales is in my opinion an anathema; a violation of the credo espoused by the industry in which I am a licensed agent for more than 45 years, a violation of the Million Dollar Round Table credo of fair sales practices.
If proposed Rule 2821 duplicates current supervision and suitability requirements that are already in place it is important the insurers and brokerage companies complete the necessary compliance and support fair sales practices.
I see this proposal as a means to re-enforce existing legislation; which has failed. Even if the percentage of complaints is lower than those recorded for security stock brokers and brokerage firms; it is too high a percentage.
Consumers have been harmed and would best be aided by making these products less available to people who do not understand risk and the failure of hiigh commissionable products to give the clients what they need as well as believe they are purchasing.
For these reasons, I urge the SEC to approve NASD proposed Rule 2821. Thank you for your consideration of my views on this matter.