Subject: File No. S7-14-08
From: xxxxxxxxxxx
Affiliation: xxxxxxxxx

November 13, 2008

Dear Sirs,

As a practicing Certified Financial Planner I must strongly encourage you to pass your proposal to label "Index Annuities" as securities and require individuals representing them to be securities licensed, and subject to the higher standards so implied.

Time after time we have seniors come to us asking us to help them with these complicated, expensive and substantially illiquid securities.

We have individuals in their 80's who will not be able to access their funds for up to a decade, without onerous charges.

As a licensed insurance professional, I am solicited by "no name" insurance companies offering me outrageous commissions for selling these products. Not much is said in these advertisements about how good they are for the client.

Any asset that purports to use STOCK MARKET returns as the basis of its returns ought to be considered a security.

State licensed insurance agents (who are not Registered Representatives) do not have the training, knowledge or compliance structure to competently offer securities.

We see the damage that is done by these unqualified persons. We see the result when nothing, short of taking a significant loss, can be done to provide a senior with much needed funds to live on, meet a health emergency, or to assist family.

Please discourage high commission, long surrender fee index annuities by moving them into the realm of the securities professionals and a higher level of investor protection.

Jeff Harring, CFP
Vice President - Financial Planning
Raymond James & Associates