November 14, 2008
I am writing to voice my support for the above referenced rule change. I am a 15 year veteran of the financial services industry, a Certified Financial Planner and carry the Series 7, 63, 9, 10, 31 registrations. I am a member of the Financial Planning Association and have served on the board of the local chapter for the last 4 years. I also have my insurance license for health and life.
I have several clients who have been presented with index annuity products over the last ten years or so. In no case did the insurance agent properly disclose the material facts of the product they were selling. I have a problem with the inconsistent disclosure required for this product versus a variable annuity. Annuity products are very confusing and since they require a long commitment in the product I strongly urge more disclosure regarding their liquidity, costs and general suitability. All consumers are vulnerable in this area but obviously it can be a much larger problem for elderly clients who have more potential liquidity needs.
I realize that many in the insurance industry do not want these products to be subject to the same rules as variable annuities. One should ask themselves this basic question - If Index Annuities serve as a perfect solution for client's needs, why would they oppose more disclosure?
Thank you for your time and attention in this matter.
Nancy S. Russell CFP®, ChFC
Associate Vice President
Financial Advisor
Morgan Stanley
Investment Consultant
Estate Planning Consultant