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anil vazirani letter to senator

Anil Vazirani's letter to Senator Patty Murray regarding Investment Adviser Protections for
American Annuity Investors:

June 22, 2017

The Honorable Senator Patty Murray


154 Russell Senate Office Building
Washington, D.C. 20510

Re: Investment Adviser Protections for American Investors

Dear Senator Murray,

Despite its reluctant implementation this month, the U.S. Department of Labor's Fiduciary Rule
remains under attack, and we must not allow its unscrupulous opponents to prevail in their efforts
to reverse or weaken this critical safeguard for American investors. Given your record as a
Senate champion of consumer protection and individual retirement investors, I respectfully urge
you to do the following:

Oppose the Financial Choice Act, which, among other harms, would reverse outright the
Fiduciary Rule's conflict-of-interest protections, as it comes before the Senate;
Remain vigilant over the Labor Department's ongoing review of the Final Rule and its effect; and,
Work to ensure that the Securities and Exchange Commission fulfills its role in protecting
vulnerable and unsophisticated seniors and retirees from the predatory marketing practices of
insurance companies, their marketing organizations, and agents who are seeking to undo the
Rule's fiduciary standard so they can continue to reap high commissions, bonuses, and rewards
at the expense of unsuspecting investors.

Like you, I expressed my strong support for the Fiduciary Rule in a public comment on the Labor
Department's proposed delay on applicability of the Final Rule, which you can find here, as well
as in an expert commentary published on Law360.com, which you can find here.

For years, independent marketing organizations (IMOs) and the insurance companies that back
them systematically have misled investors by preying on their fears and forcing high-fee, complex
proprietary fixed indexed annuities (FIAs) on them regardless of whether the product was in the
investors' best interests. The designers of complex proprietary FIAs lure insurance agents with
potentially high commissions and annual bonuses. They also incentivize IMOs marketing these
complex proprietary FIAs with protected margins of commission and limited distribution models
that ultimately hurt investors due to the deceptive marketing nature of these particular FIAs. The
industry and its trade groups, in particular the National Association for Fixed Annuities (NAFA),
whose members are storming Capitol Hill this week, are continuing to wage war against the Rule
in an aggressive effort to overturn it through litigation, as well as public relations and lobbying
campaigns.

The designers of these complex proprietary FIAs Annexus Group, Market Synergy, and
Innovative Design Group and the insurance companies and distributors that back them
notably Nationwide Insurance Company, Security Benefit Insurance Company, Aviva Life &
Annuity Company (recently acquired by Athene Insurance Company), Advisors Excel LLC, and
Creative One Marketing Corporation induce, or at a minimum, cause insurance agents to give
investment advice without an investment license. They also commit source-of-funds violations by
influencing the movement of money from securities into complex proprietary FIAs without the
proper securities license, and potentially abuse the principle of past performance not being
indicative of future results by using hypothetical illustrations to project non-guaranteed returns.

We must ensure that these unregulated, unscrupulous practices are permanently erased from the
investment marketplace.

I share your passion and commitment to protecting American investors from misleading marketing
practices and predatory sales practices as they relate to complex propriety annuity products.
Having worked in this industry for decades, I am well-acquainted with those corrupt entities in the
industry whose marketing presentations and instruments have a propensity to mislead.

I stand ready to offer my years of insight into the corrupt practices of IMOs and other insurers,
including providing specific evidence of IMOs' misleading marketing tactics and conversations to
skirt regulatory scrutiny. Thank you for your consideration.

Respectfully yours,

Anil Vazirani

Anil Vazirani ( LUTCF )Member: BBB , NAIFA , NEB


Independent Insurance Advisor
Series 65 Investment Adviser Rep
2004 SSMP Hall of Fame Inductee
HS Dent Master Certified Member
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