From: Larry J. Winkelhake |
Dear Ms. Morris, As a licensed insurance professional who sells Variable Annuity Products I am writing with regard for the suitability and principal review requirements pertaining to the sale of Variable annuities contained in NASD proposed rule 2821. While the proposed rule's requirements are redundant and unnecessary and will not provide meaningful protection to consumers it will greatly impact my business. I urge the SEC to disapprove the proposal. Agents and Representatives who engage in misleading sales practices need to be prosecuted and made subject to appropriate sanctions. Currently the NASD cannot justify the need for this proposed rule. Unsuitable Variable Annuity sales made up less than .50 percent of the NASD's disciplinary actions over the last five years. Furthermore, the majority of comments received by the NASD and SEC regarding the proposed opposed these new rules. Further, the proposed rule 2821 duplicates current supervision and suitability requirements currently in use. NASD rules already contain suitability requirements that apply to all sales of securities. If we really want to protect consumers, appropriate action on the existing suitability rules rather than new rules is the answer. I urge you to disapprove NASD proposed Rule 2821. Enforce what we already have on the books. thanks for giving me the opportunity to voice my opinion on this matter. Best Regards, Larry J. Winkelhake, CLU, ChFC Larry J. Winkelhake, CLU, ChFC |