Subject: File No. S7-14-08
From: Mike Whittenburg
Affiliation: CLU, ChFC, REBC, CASL

October 21, 2008

I believe that agents who sell Equity Indexed products should be series 6 licensed. I have read all of the reasoning behind the guarantees of insurance companies etc. The problem is that in my experience, in the cases I have reviewed and in sales presentations I have witnessed, the agents have used the opportunities available in the stock market and huge potential returns as the primary focus. Having the huge upside but with a guarantee makes it sound too good to be true. There are so many misunderstood rules, fees and charges that it is almost unethical, especially when comparing an Equity Index presentation to the disclosures of a Variable Annuity or even a mutual fund sale. At a minimum the same disclosures of inside fees, surrender charges and penalties and time frames must be required. Far too many people do not understand what they are selling and what they are buying. Too many agents think these products are magical. By requiring the agents to complete a disclosure form, at least they will learn a little something about what they are selling.