September 2, 2008
Dear Sirs: RE: File number S7-14-08
I am a Certified Financial Planner working here in Waconia, MN. I have over thirty years of experience working with families in retirement planning. I am writing about the proposed rules change (#151A) recently published by the Securities and Exchange Commission. The agency is seeking comments on this rule until September 10, 2008.
The SEC is seeking to require that all fixed index annuities become registered products sold only through a broker dealers, and not by insurance agents. Even though I am a Registered Representative, I feel this is putting too much of a burden and an unnecessary one, on the insurance industry and its dedicated agents.
This would be bad for both the industry and for consumers. These products are not securities by definition. The indexed annuity offers the consumer a strong minimum guarantee backed by the insurance company, along with the opportunity to earn excess interest.
In addition, the proposed rule adds no consumer protections not already provided by state insurance regulations. Most states have already adopted the NAIC Annuity Disclosure Model Regulation, and the insurance companies with which I work conduct suitability reviews of sales in all states.
To require a securities license to sell these products would be onerous. I have taken these classes. While it may be good information to know, it has very little application to index annuity products. Both agents and the insurance companies would suffer, and the consumers would receive little or no benefit, in my opinion.
Sincerely,
Ronald C. Kolb, CFP