Subject: File No. S7-14-08
From: Charles J. Wagner, MBA CFP®
Affiliation: Spence Asset Management

November 13, 2008

Dear SEC,

I urge you to take a favorable look at adding oversight to Index Annuity sales. As a Certified Financial Planner and an active member of the Financial Planning Association (FPA), I have been bothered by what I call unscrupulous sales tactics – especially targeted toward the elderly and aging – by agents representing themselves as experts in senior wealth management. I believe many people are targeted for sales of these products and are unsuitable for their retirement planning. Many of my clients call me with stories regarding seminars they attend or sales pitches from travelling representative that promise them the best solution to their current or future income needs, without risk. These sales pitches are misleading at the least and downright fraudulent in many cases. Rarely are disclosures regarding liquidity, surrender charges or other suitability factors properly disclosed. I strongly support the proposed Equity-Indexed Annuity Rule.

Sincerely,

Charles J. Wagner, MBA CFP®
Spence Asset Management