November 17, 2008
Dear SEC,
My name is Robert Bryan Burkey and I support the proposed rule for File No. S7-14-08. I am Certified Financial Planner and a member of the Financial Planning Association (FPA), the National Association of Insurance and Financial Advisors (NAIFA) and the Million Dollar Roundtable (MDRT).
Again and again and again I am confronted with "insurance" people selling investments to my clients. JUST TODAY I received yet another call. Same story, same circumstances. These unlicensed advisors are calling my clients and trying to sell them products with very long surrender charges that pay high commissions. These crummy insurance companies win, the lousy, unprofessional insurance person wins, but the client loses in almost every circumstance.
Rule S7-14-08 is reasonable and enhances state enforcement efforts. Our vulnerable, aging population needs additional protection from aggressive sales agents. Consumers are often misled regarding the benefits of an indexed annuity. Liquidity risks, surrender charges and other suitability factors are not always clearly disclosed or understood. Not all states have adopted suitability standards for annuity sales, nor do most insurance commissioners have adequate enforcement resources available. Some agents misrepresent themselves as offering a single retirement solution when in fact retirement planning is generally a complex planning process.
Thanks you for your time and I hope this issue is considered more closely.
Sincerely,
Bryan Burkey, CFP®, CLU
Financial Planner