November 13, 2008

Subject: File No. S7-14-08

Please accept this email as my support for the proposed rule the Equity-Indexed Annuity Rule. My name is Tina Towery and I am a registered representative (1996), a Certified Financial Planner (2001), a member of the Financial Planning Association and a licensed insurance agent in the state of Florida (2003). I am not currently working with clients, because I am at home with a baby, but I was most recently employed as a compliance officer for a municipal bond dealer in 2007. During my work there with many elderly clients, and as the officer responsible for state insurance licensing registration, compliance and continuing education, I never once witnessed what I would consider reasonable oversight by the State. I agree strongly with the FPA recommendation that the rule is a reasonable and balanced approach to enhancing state enforcement efforts and that problems with the current regulation are:
a. the vulnerable aging population needs additional protection from aggressive sales agents
b. consumers are often mislead regarding the benefits of an indexed annuity
c. liquidity risks, surrender charges, and other suitability factors are not always clearly disclosed or understood
d. not all states have adopted suitability standards for annity sales, nor do most insurance commissioners have adequate enforcement resources available
e. some agents misrepresent themselves as offering a single retirement solution when in fact retirement planning is generally a complex planning process