Subject: File No. S7-14-08
From: Bob Ponton, CFP®
Affiliation: First Command Financial Services, Inc.

November 13, 2008

Dear Sir/Madam,

I am a Financial Advisor and member of the Financial Planning Association. I strongly support the proposed rule regarding indexed annuity sales.

As a member of the Financial Planning profession working with client families for seventeen years, I fully realize retirement planning is a complex planning process. Therefore I realize those agents who may be offering their clients a single retirement solution are most definitely not working in the best interests of their client. In my view, the rule is reasonable and balanced and will, in the end, enhance state enforcement efforts.

Thank you for your time and thoughtful consideration.

Bob Ponton, CFP®
Financial Advisor
First Command Financial Services, Inc., parent of First Command Financial Planning, Inc.