Subject: File No. S7-14-08
From: Gary S Haft
Affiliation: Certified Estate Planner - AACEP

September 2, 2008

I agree that the SEC and/or FINRA SHOULD take control over Indexed Annuities because of the improper sales to seniors. Agents who are insurance only licensed sell Equity Indexed Annuities because they are not licensed or do not care to be licensed for Securities and the potential sales of Variable Annuities.
I know too many seniors that have been hurt by these unscrupulous agents and now, if this rule passes, will be forced to get their securities license in order to continue selling these Equity Indexed Annuities. Many of these insurance agents will be forced to stop selling these EIA's because they have no desire to take a securities exam AND get involved with a Broker-Dealer. Many Broker-Dealers require a minimum production of sales in securities and therefore these agents would not likely sell securities or have the minimum requirements needed to meet the Broker-Dealers minimum standards. Many of these insurance agents do not want to deal with compliance issues either and have never bothered to apply for a securities license knowing that compliance issues would stop them from many of their current sales practices.
GLAD TO SEE THIS IS HAPPENING Hope it passes. GOOD LUCK