From: John Harvey
Dear Sir or Madam,
I would like my position on the proposed rule concerning variable annuity sales to be clear. I do not think it is necessary or wise to require GREATER disclosure on the sale of variable annuities over that of other investment products. The same is also true when discussing suitability requirements. This will only add to the already heavy burden that registered representatives and principals have to bear but also to our clients which may get more confused by additional paperwork and disclosure forms rather than less confused. It is the responsibility of both the representative as well as the client to disclose and understand the material facts regarding variable annuities. Implementing the proposed change may impose the neccesity of hiring additional employees to a small firm. This may be very unreasonable in light of the size of the firm and the amount of VA sales it issues. I would ask that you reconsider this rule and the cumbersome forms and disclosures that go with it. Thank you.
John Harvey, CSA
Endorsed Local Provider for Dave Ramsey
Malachi Financial Group