Subject: File No. S7-14-08
From: william h simpson, CLU, ChFC

September 9, 2008

I agree 100% that many if not most sales of indexed annuities are sold without full disclosure and may be an improper product for the client. BUT I do not feel you have the power or right to make legistation.
Indexed annuities are insurance products by definition and law so they should properly be govern by the states currently. The Federal Government through the congress should give the states notice of the problem and if they do not correct the situation, then change and have ALL insurance under the Federal Government control. I sincerely doubt the states will correct the problem but the mislead clients can use the courts to get their situation corrected.
I am a pretty informed agent, who does not sell this product, as I have trouble knowing on which products the surrender charges apply at death.
As a registered rep. i have access to the variable annuity products, which are usually a better solution for the older age client.
Maybe with your constant pressure the industry will respond.