November 13, 2008
To Whom it May Concern:
I firmly support the SEC rule to consider the Equity-Indexed Annuity a Security , thereby making it subject to SEC & Finra regs.
I'm a member of the FPA and in my 16 years of experience have seen many examples of unsuitable sales of Equity-Indexed Annuity sales in that the clients had no idea what they were purchasing. They just did not know or understand the product!!
Many consumers are misled as these are complex products and the clients (consumers) do not understand the liquidy risks, surrender charges as they sold by individuals that do not necessarily have the the training in these complex products.
In addition, it is not clear if the oversight by the Insurance Commissioners from state to state is consistant? This could result in an unbalanced enforcement thereby exposing senior citizens to the possibility of aggressives sales agents (unregulated) taking advantage of an aging population.
Sincerely,
V.E. "Gene" Lambert, CFP®, CDFA™
CERTIFIED FINANCIAL PLANNER™ professional
AXA Advisors, LLC