Subject: File No. S7-14-08
From: Brandon W Morgan, CFP

October 13, 2008

Indexed annuities that are 2 tiered and have a greater than 10% surrender might need additional scrunity.Also annuity commission above 8% should be regulated. But index annuities of 9 years length or less should not be regulated. As the market is extremely volatile investors need a safe haven,but still want to participate in the market upside. Many times small investors do not have access to a Registered Investment Advisor who act as a Fiduciary and if they go to s stockbroker there is no fiduciary duty.There does need to filled out a suitability form for all annuities.These insurance agents do have a duty to the client and hopefully they will do it faithfully.