Additional information regarding investing in variable annuities should be added to the current prospectus that investors already receive, rather than in a separate document, the Securities Industry Association
proposed in commenting on the NASD Notice To Members dealing with deferred variable annuity sales practices. SIA believes this will supply investors with clear, meaningful information regarding the unique features of variable annuity products in a form that does not duplicate material already in the prospectus. Doing so will also encourage investors to read the document.
SIA also suggested that the NASD’s proposal giving registered principals one business day to review, approve, and sign off of a transaction would adversely affect a client's ability to invest in a deferred variable annuity in a timely fashion. SIA recommends that the same rules governing registered principal review of all other recommended security transactions apply to variable annuities.
The letter is available at http://www.sia.com/2004_comment_letters/2295.pdf