From: Steven M. Weinstein, CFP
Having served the public whom you're attempting to protect since 1982, I object to this amendment, referenced above.
Please take note that, in my nearly 25 years in the securities sales business, I have never had a complaint or lawsuit filed by a customer.
My objections are several:
First, additional disclosure documents and suitability requirements will do absolutely nothing to further protect investors. Paradoxically, they will harm investors. In my practice, for example, investors often refuse to read materials which have resulted from past actions by regulatory bodies. As they say, ' that's why I hire you'. Further, I see reps sell unsuitable products because it's difficult to stay in business living on 100% commissions in a context where there's public distrust mainly from INVESTMENT RISK ...so now you burden them further??????????
Second, annuities are bought and held by the public as investment products, not life insurance meant to fund beneficiaries (extraordinarily) in the event of unexpected death. Afterall, beneficiaries only annuitize out of ignorance of their forfeiture or to receive better tax treatment of their proceeds. The proposed amendment would appear authored by academics who misconstrue a suitability connection between real life insurance and an investment contract marketed by life insurance companies. Not so.
Third, and while it may make you nervous, what's important is that reps understand annuities; their structure in an absolute and relative sense, their benefits and drawbacks in the hands of prospective investors, relevant tax law, etc. If harmed or otherwise unhappy, customers should complain to reps whose broker-dealers earn their keep by supervising them. KISS
Steven M Weinstein, CFP