Subject: File No. S7-14-08
From: Walter F. Williams, MBA, CFP®, CRPC
Affiliation: Sagemark Consulting^SM

November 13, 2008

As a financial professional and CFP certificant, I urge support for File No. S7-14-08 requiring security oversight of index annuities. The vehicles are securities driven and their representation should only be presented by a securities professional. My experience is that someone not familiar with securities does not adequately portray the potential pitfalls as well the pros of these vehicles.

Walt
Sagemark
Consulting^SM
A member of Lincoln Financial Group

Walter F. Williams, MBA, CFP®, CRPC