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Home > Financial Services > Stock Brokers > Park Avenue Securities Llc
Park Avenue Securities Llc
Park Avenue Securities Llc is a member of NASD, the National Association of Securities Dealers. NASD is a self-regulatory organization of the securities industry responsible for the operation and regulation of the NASDQ stock market and over the counter markets. It also administrates exams for the investments professionals, such as the series of 7 exams.
The company is a broker-dealer that is indirectly owned by The Guardian Life Insurance Company of America, a New York mutual life insurance company, and is registered with the United States Securities and Exchange Commission and a member firm of the NASD. Substantially all of the approximately 2,800 registered representatives of the company are also career force insurance agents of Guardian.
Broker-dealers affected by NTM 99-35 have now had almost five years of experience, utilizing its guidelines. They support a regulatory approach that leaves it up to each broker-dealer to develop and maintain specific procedures that follow the guidelines included in NTM 99-35. The company invites senior NASD representatives to engage the industry, including insurers, in an open dialogue prior to any rulemaking regarding setting specific standards with regard to age, contribution relative to income or net worth, marital status or tax bracket. For many of these factors, they believe that there is a need for flexibility on a case by case basis.
The company appreciates the opportunity to comment upon the proposed Rule and looks forward to a meaningful and open dialogue with the NASD, the insurance industry and the SEC to better coordinate regulatory efforts and ensure that variable annuity sales are not associated with unsuitable sales practices or poor supervision.
In Other Comments on the Proposed Rule PAS offers three additional comments on the proposed Rule. First, NTM 04 to 45 contains no discussion of distribution channels or group sales. If the NASD deems it appropriate to specifically regulate deferred variable annuities then appropriateness standards ought to reflect issues germane distribution through wholesale broker dealers and group sales such as through ERISA-qualified retirement plans. The company submits that in such cases the NASD ought to clarify just who is responsible for suitability determinations and the content of those determinations.
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