for wealthy individuals who are not able to contribute to a Roth IRA due to IRS income restraints. It is illegal to market Index Universal Life (IUL) as an "investment security", as defined by the Securities Act of 1933 & the Securities Act of 1934. These Acts of Congress gave birth to the SEC, in reaction to the stock market crash of 1929 that preceded the Great Depression. Today, the SEC oversees FINRA and they both regulate the marketing and sale of securities. IUL is an insurance product and does not meet the definition of a security, so it does not fall under the authority of the SEC or FINRA. Therefore, under the authority of the SEC and FINRA, Index Universal Life Insurance cannot be marketed or sold as a "security", "variable security", "variable investment" or direct investment in a "security" (or the stock market), because it is not. However, IUL can be marketed and sold as an investment. High commissions, conflict of interest Agents receive higher commissions for selling universal and other whole life policies than they do for selling less expensive term life insurance, leading to concerns about conflicts of interest. Proponents respond that it would be inaccurate to state that term insurance is less expensive than universal life, or for that matter, other forms of permanent life insurance, without qualifying the statement with the other factor: Time, or length of coverage. While term life insurance is the least expensive over a short period, say one to twenty years, permanent life insurance is generally the least expensive over a longer period, or over one's entire lifetime. This is mainly due to the high percentage of the premiums paid out in commissions during the first 10–12 years. Misunderstood risk to policyholders Interest rate risk: UL is a complex policy with risk to the policyholder. Its flexible premiums include a risk that the policyholder may have to pay a greater than planned premium to maintain the policy. This can happen if the expected interest paid on the accumulated values is less than originally assumed at purchase. This happened to many policyholders who purchased their policies in the mid-1980s when interest rates were very high. As the interest rates lowered, the policy did not earn as expected and the policyholder was forced to pay more to maintain the policy. If any form of loan is taken on the policy, this may