Subject: File No. S7-14-08
From: Richard G Ek, LUTCF
Affiliation: Member of NAIFA since 1975

October 13, 2008

The interest rate guarantees basic to every Fixed Index Annuity separate these contracts from everything sold under the purview of the SEC.
One of the primary reasons behind the idea of taking Fixed Index Annuities out of the arena of non-registered agents seems to be at the request of registered representatives who have seen massive transfers away from their control.
The companies I deal with have a certification process for all agents that must be passed before any solicitation of Fixed Index Annuities can take place. I steer clear of any companies that do not require such a test for agents.
I would like to see all insurance companies required to put in place a certification process to make sure agents know the product, understand suitability and proper service.