Subject: File Number S7-14-08

August 26, 2008

Dear Cliff,

I just wanted to write and tell you how unhappy I am that NAIFA has decided to oppose the SEC’s proposed regulation of Equity Indexed Annuities. Several years ago NALU changed its name to NAIFA which was to give us a much larger umbrella for membership. Most decisions made by NAIFA still seem to favor the insurance industry.

Currently, insurance only licensed agents are free to tell any lies or misrepresentations they want without any real controls. We have agents from Phoenix coming up here to Tucson and Raping and Pillaging residents with their seminars full of lies about Variable Annuities, Mutual Funds and other investments. They then go to a home for an appointment and ask to review their investment statements and try and convince them to sell everything and put all their money in an EIA. They don’t do this for the clients benefit, they do it to collect a huge commission and tie the money up for years with high surrender charges and long surrender periods. I keep a box of Kleenexes in my office for people that come into my office and actually cry over what happened to them. I have been successful in getting some people out of these contracts but, most come to me too late.

I am now part of Commonwealths Registered Investment Advisor program and it greatly disturbs me to see these things going on without any oversight. We are to do what is in the clients best interest not what is best for our own pocket book. If EIA’s were the very best thing for a client why would I spend a lot of hours researching investment opportunities for my clients and keeping a constant watch on those investments for an income that is far less than the commissions on EIA’s where I could just sell it and forget it. That is what these EIA people are doing. The only reason they make follow up calls is if there is some money that they didn’t get the first time, they will hassle the client over and over trying to get it.

One of the biggest false statements they make concerns the huge fees that they claim VA’s charge while there are no fees on an EIA. Anyone that has looked at the actual returns of the EIA indexes vs what the client gets credited will see that many times the client gets 9% of an actual gain in the index of 17%. In my book the EIA had an 8% fee in that case. They also claim that you can lose all your money in a VA but, VA’s often have better guarantees than an EIA.

Cliff, I have known you for a long time and I hope that in your reign as President you will try to widen the umbrella and be proactive in trying to bring integrity back into our business. I hope that you will reexamine the decision to fight the SEC and do what needs to be done to provide for the best interest of the consumers.

Have a great day!

John R. Peters, CLU, RHU, CPCU, ChFC
Professional Wealth Strategies
Financial Adviser*