November 13, 2008

Subject: File No. S7-14-08

a. My name is Joseph M Conwell of Lesko Securities, Inc. a wholly owned subsidiary of Lesko Financial Services, Inc.
b. I am a member of the Upstate New York FPA and I SUPPORT the proposed rule.
c. We are an independent insurance and securities firm in Binghamton, NY
d. I have been licensed in securities and insurance since 1992. I support ethical Financial Planning and ethical sales practices.
e. The travesty I continually see is lack of oversight in the sales practices regarding unsuitable equity indexed annuity sales. They consistently display lack of knowledge of equity markets, insurance laws
f. and use fear and greed in order to promote these products.
g. Problems without the proposed regulation:
a. the rule is a reasonable and balanced approach to enhancing state enforcement efforts
b. the vulnerable aging population needs additional protection from aggressive sales agents
c. consumers are often mislead regarding the benefits of an indexed annuity
d. liquidity risks, surrender charges, and other suitability factors are not always clearly disclosed or understood
e. not all states have adopted suitability standards for annuity sales, nor do most insurance commissioners have adequate enforcement resources available
f. some agents misrepresent themselves as offering a single retirement solution when in fact retirement planning is generally a complex planning process

Joseph M. Conwell
Financial Consultant
Lesko Financial Services, Inc.
Lesko Securities, Inc.