Subject: File No. S7-14-08
From: Willuiam T. Hagen, CFP

September 10, 2008

I would sincerely urge a study conducted by a third, non biased party, such as a university to inform Congress of the pros and cons of Equity Indexed Annuities. I feel there is a strong chance certain congress people have been unduly influenced by certain other third parties to believe concerns concerning indexed annuities that simply are not true. Most of my clients are recently divorced women who do not have a clue about their retirement. Putting what usually is their largest asset in the hands of a broker or in other words "the market" is insane. These monies (401(k)) derived from a divorce which many times these women did not want, is the best and only source of retirement monies these women will ever have. They simply can not risk any of these funds at the hands of possibly commission happy brokers (churning pros) or the whims of the market. They need the opportunity to have their monies grow in some proportion of the growth of the market if there actually is market growth yet protected with the strength of an insurance market.
Using EIA's (Equity Indexed Annuities) is the only option they have to accomplish this goal. Mutual funds is not the answer. Variable annuities is not the answer, a diversified portfolio is not the answer because all of these options have market risk. Their retirement asset can not risk failure.
EIA's provide an increase in their funds due to market growth without the risk of the actual market.
Please look and see who stands to gain monetarily by forcing insurance companies to comply with rules completely not in harmony with the basics of the product called EIA's.
I submit to you, broker dealers will gain substantially and the actual cost of
I am not suggesting some idiots have not abused the selling of these products. That will and has occurred no doubt because certain people are just basically dishonest but please do not put EIA's in the same category as an investment because they are not. They can increase in value, they do pay off should death occur, they can create a retirement monthly income so many are looking forward to.
Just study this out in your own mind. No owner of an EIA can lose money and a monthly income can be generated. That is more than the Federal Government will say about the social security system these same people were relying on.

Thanks for your time.

Bill Hagen, CFP