July 30, 2008
I am opposing Sec 151A.
This rule does not make any sence.
If you follow the logic all life insurance ploicies could and should be declared as securities. No other securities are offering guarnteed returns at a minial level.
I am licenced in both securities and life insurance and the broker dealors that I have been associated with are not equiped to evaluate insurance products with guarantees.
Thanks
Howard D Crissey CLU, ChFC, RFC