Subject: File No. S7-14-08
From: Randall G Knowles, ChFC, CFP, SPHR, LUTCF
Affiliation: ChFC, CFP, SPHR, LUTCF, BS Economics

September 2, 2008

FINRA regulation of Equity Indexed annuities will NOT reduce the regulations already established by the states. FINRA has always succumbed the to states regulations. This action will only create confusion for the consumer the very person we are trying to help will bear all the pain.

To whom will the customer turn, who has already purchased an Equity indexed annuity, if it falls under the proposed FINRA rules? Annuities are purchased by people from advisors whom they trust. Advisors are usually more involved in the retirement, estate, and income needs of the client than just the mere sale of an annuity.

If FINRA deems equity indexed annuities a security then they must be prepared to also claim fixed annuities and certificates of deposit to fall under the same rules. FINRA must therefore carry through and require all bankers to be security licensed.

For, in essence, FINRA will be requiring all insurance agents to be security licensed.

Regulation will never replace ethics and as long as humans roam the earth there will always be one that is unethical.