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Your assumption is correct. Principal will be invaded to pay the penalty equal to interest CD would have earned. In regards to surrender charges on FIA, it's a misnomer. It's a contingent deferred sales charge. When a registered rep sells B shares they get a lumpsum commission. Investment company recupes this marketing cost annually from their fees during the initial years. If the investor makes early distribution they pay the sales charge (dealer commission) according to number of years their money was invested. The same happens with cash value life insurance (including WL). Don't worry about FINRA. At the current rate of reps leaving them to become RIAs they will soon collapse on their own. Just don't go get security licensed and prolong their demise.
Not to rez a dead thread, but I thought I would comment here.
When I last posted on this website, I was a Series 7/66 broker under an indie broker dealer.
Since leaving, dropping my 7 and starting my own RIA firm (maintaining my Series 65/66), I am happier, less stressed, make about the same amount of money, and most importantly of all, kicked the corrupt and incompetent SRO known as FINRA out of my career and life.
As a state regulated RIA, I still have regulations, but I find the States and the SEC much more sane when allowing me to run my business the way I want to and take care of my clients. It's no wonder FINRA is trying to angle now to take over RIAs, but the states are fighting back - they don't want to lose control, and more importantly, their RIA registration and licensing fees.