Subject: File No. S7-14-08
From: Connie Roth
Affiliation: LUTC

September 2, 2008

I am totally opposed to having an insurance product, "indexed annuities" under another level of regulation such as SEC and FINRA.

Securities regulations adds little benefit to consumer protection as well as member protection. I was an agent for an exclusive captive agency and had a personality conflict with my Distict Manager. She made up allegations and placed them on my Form U5 and blackballed me out of the industry forever. I was cleared by FINRA, however, of any wrongdoing, but am still guilty after been found innocent, because of this process with FINRA. The allegation of not witnessing a customer's signature was even provided with an affidavit from the customer that my customer signed this document 3x in my office as the insurance company had consistently and conveniently lost it. So you see FINRA did not even protect the customer, my insured, nor did they provide the member any protection, as they believed what the broker had placed on the U5. My contract was terminated from this broker and this insured no longer does business with this insurance broker who misrepresented and lied to her and continues to be my customer today. The securities regulations added VERY LITTLE BENEFIT TO THE CONSUMER PROTECTION AS WELL AS MEMBER PROTECTION.

Captive Exclusive Insurance Brokers are using the Securities industry and regulations to do their dirty work. These brokers can make up anything and place on an agent's U5 and it is up to the agent to spend thousands of dollars to try to clear themselves and then once cleared it is almost impossible to get the items expunged from their U5. I have been an agent with this broker for nearly 9 years, with NOT one customer complaint and had received the numerous awards every year from the Broker. I worked for a major corporation for 12 years with OUTSTANDING EVALUATIONS AND MANY PROMOTIONS. I served on the Board of the Dupage Life Underwriters for 2 years and was involved with my Chamber of Commerce. A leopard does not change his spots after many years of good work ethics and accomplishments. One of the items put on the U5 was involved in outside business activities. It was not until I was investigated 1 year later that I knew what this was about. It was about joining the Chamber of Commerce and not updating my U4. It was also purchasing vitamins for my very sick mother who I was home health care provider for and the broker dealer accused me of selling the vitamins and not updating my U4. This would have been very easy to prove. Ask for my W4's and one could see that I was NOT involved in any outside business activity. However, this exclusive captive company had a different agenda as they did not want to know the truth. It is called churning of agents books of business as it is a big windfall for an insurance captive insurance company. They can make up false allegations, steal that book of business and assign that book to another agent, and not pay any commissions on it for the 1st year, and substantially less commission the 2nd year and thereafter.

I am totally opposed to putting indexed annuities under another regulation such as FINRA and SEC as they are already regulated under the State and by putting them under another level, only provides captive insurance companies such as State Farm, Nationwide, American Family, Farmers, Country, etc. a license to steal against their independent insurance agents.

See the attached articles from www.NAFFA.com and the attached spreadsheet of the churning of agencies books of business from one captive insurance carrier, American Family, who has a business plan in place to churn agencies books of business as their ACP Plan has spiraled out of control and they need to get it back in sync.

One only has to get on the website of the American Family Association of Agents to find out what this company is doing and how they are using the FINRA to do the dirty work and terminating and ruining agents lives after many many years of building an agency and working for their retirement, www.naafa.com

Also, wanted to send you a letter that NAAFA recently sent out to a Wisconsin Senator on behalf of an agent in Wisconsin. ("comments attached"). Also on the NAAFA website, Connie and I are beginning a series of what has happened to us. One has to join NAAFA to read the inside stories but on the public website there is a teaser. I have attached the first part of a 3 part series. Below is the teaser that is found on the public website:

Teaser

8/2/2008 — NAAFA BREAKS WITH TRADITION..AUTHOR IS NAMED

NAAFA BREAKS WITH TRADITIONAUTHOR IS NAMED. Posted August 2, 2008

NOTICE TO MEMBERS: YOU MUST LOG IN TO READ THIS ARTICLE. LOOK FOR:

HISTORY AND EVENTS LEADING TO OUR TERMINATION AT AMERICAN

FAMILY by Connie Roth ("Comments attached"

Rumors always fly when an agent is terminated. For some unknown reason, the agent

usually is the bad guy in the eyes of his co-horts and definitely in the eyes of the company.

Often only the companys side is told and, of course, the company makes themselves look

good. If an out-of-court settlement is made, theres usually a gag order. Isnt it time you

heard the agents side of the story? You must decide whom you choose to believe. We

suspect that after you read Connie Roths article about her termination and the termination (at

the same time) of her twin sister, Bonnie Roth, you will begin to have your eyes opened.

The Roths will be presenting a three part series for members only. Obviously, Part 3 is not

history yet. It has been over three years since the Roth agents started fighting this battle.

They are to be commended for standing for truth, for trying to make things better for all

agents, and for doing this at such a great cost to them.

1) History and Events Leading to Our Termination at American Family.

2) The FINRA Investigation and Succeeding Court Events

3) The Outcome of Roths Legal Pursuit of Fairness and Equity

Please note that NAAFA is making an exception to their rule of never divulging the name of contributors to

our website or newsletter. The Roths have requested we use their name in an effort to lend credibility to their

story. We salute them and wish them well in their endeavor to stand up for what is right. If you would like to

contact either Connie or Bonnie Roth, they can be reached at 630-907-0611 or Email them at:

croth@rothinsurance.net.

The History and Events Leading to Our Termination by American Family
by Connie Roth 8/2/2008

See Attached Article

(Attached File #1: s71408-1330a.pdf)

(Attached File #2: s71408-1330.pdf)