Subject: File No. S7-14-08
From: Jeremy S. Mitchell, CFP®
Affiliation: Financial Planner

November 13, 2008

To Whom It May Concern:

Though I do not sell Equity Indexed Annuities, I believe that, as fixed annuity products, they should be regulated only by the state insurance commissions. However, given this belief, I have a number of concerns regarding said products and their sale:

1. I believe that insurance commissions must crack down on the unsuitable sale of these products to the elderly.
2. There must be disclosure requirements for surrender periods, charges, and inner workings to potential investors.
3. Suitability guidelines, based on the clients’ financial situation, must be implemented, followed, and enforced.

I believe these products, as they guarantee the investor’s principal, fit into the realm of fixed insurance products, and that to add them to oversight by the securities law would be unacceptable. However, I do not believe that most state insurance commissions have acceptable rules regarding the sales of these products.

Let us keep these products aptly classified, and put pressure on the state insurance commissions to overhaul regulations as they apply to the sale and marketing of equity indexed products.

Sincerely,
Jeremy
Jeremy S. Mitchell, CFP®
Financial Planner