Subject: File No. S7-14-08
From: Joel P. Bruckenstein, CFP®

November 13, 2008

As a Certified Financial Planner and a member of the Financial Planning Association (FPA)I strongly support SEC oversight of indexed annuity sales. I have personally encountered many consumers who were sold indexed annuities with harmful results. It is clear to me that in many cases the consumer did not fully understand the product, and relied solely on the advice of a sales person who may or may not have had the client’s best interests at heart.

The indexed annuity problem is a national one, and as such it required national enforcement. Most states are trying to address the problem of inappropriate sales, but enforcement is uneven. It should be pointed out, however, that some states have not adapted any suitability standards at all.

As the population ages, and as boomers retire, we are likely to see many more abuses unless the SEC acts. Aggressive sales agents often take advantage of the elderly, and the nation owes it to our seniors to offer better protection. In many of the cases I’ve encountered, liquidity risks, surrender charges, and other suitability factors were either not disclosed by the sales person or not understood by the purchaser.

I am also troubled by certain sales practices that portray indexed annuities as a single, one size fits all retirement solution. Nothing could be farther from the truth. Retirement planning is a complex process that requires diversification and the use of appropriate products.

Respectfully,

Joel P. Bruckenstein, CFP®