September 7, 2005
To Whom It May Concern:
I would like to make some comments about the proposed rules of SR-NASD-2004-183.
I appreciate the concerns that Variable Annuities maintain suitability. I think that training programs which meet your objectives could be enacted. I do believe that most advisors do understand the products which they are using. Unfortunately, it is only a small handful of people who are not understanding the products which are being utilized. In any event, a training program for the entire industry may help in this matter.
I would ask you to not implement the proposal for principal review before the transaction can be made. There are many types of features in various variable annuities, and it would be very difficult for one individual to understand each one. Again, I think that most advisors are knowledgeable in the products they place. Having to attain principal approval before placing the product , would only slow down the process of placing the clients money in a favorable product and possibly raise the expenses due to the extra work needed, which is usually passed along to the client. If this would need to be enacted, maybe it should be enacted to newer people in the industry, for instance, prior approval to anyone entering this industry for two years.
I also want to point out that some variable annuities which have been introduced recently offer clients benefits such as principle protection even if invested into the equity subaccounts. Many people want the potential for equity type returns, and really appreciate that they do not have to take the risk in the event we have a bear market and their accumulated value drops. No doubt, some of the newer variable annuities with these features offer great advantages to many people.
Thank you for your time.
Scott T Leverenz, CRPC
The Financial Resource Group
Cambridge Investment Research