Subject: File No. S7-14-08
From: Ken Bickel, CFP®
Affiliation: South St. Louis Group

November 13, 2008

I am in support of this proposed regulation. Even though I can offer and sell index-annuities I don't, primarily because they are so hard to understand. I find myself reviewing a client's Index annuity and related sales materials and neither of us can get a good grip on what to expect from it. But with certainty the client has some misinformed idea that they can be "in the market" without any risk. Clearly this is being touted as something that is related to the stock market with all kinds of opportunity for misrepresentation or misunderstanding and sales people should have to follow the same rules as for any other retail security.

Ken Bickel, CFP®
Financial Consultant
St. Louis-Heartland Region
South St. Louis Group