October 5, 2012

RE: Notice of Proposed Rule Making regarding Proposed 11 NYCRR 225 (Ins. Reg. 199)
Suitability in Annuity Transactions

The National Association for Fixed Annuities (“NAFA”) appreciates the opportunity to provide comments on the use of senior-specific certifications and professional designations in the sale of life insurance and annuities. NAFA’s sole mission is to promote the awareness and understanding  of fixed annuities and has partnered with a number of trade groups and industry members to promote greater consumer financial literacy.

NAFA is also a strong proponent of efforts to eliminate inappropriate sales practices and identify inappropriate sales persons. Putting measures in place to provide for an even more reliable sales environment built on mutual trust and quality service is absolutely in the best interests of the
financial services marketplace and consumers looking for retirement solutions. Making this temporary/emergency provision permanent would mark great progress in fostering this ideal sales environment. View full comment here.