Subject: File No. S7-14-08
From: Cherie Brown, CFP
Affiliation: Wachovia Securities

November 13, 2008

Dear Sirs:

I am a Certified Financial Planning Professional, a member of FPA and am a Financial Advisor with Wachovia Securities ( legacy A. G. Edwards and Sons). I have been in this position since 1981.

I support the proposed rule allowing for SEC oversight of indexed annuity sales in addition to state oversight by insurance commissioners. I firmly believe that any agent selling these indexed annuities should hold Series 7 and/or CFP and/or be a Registered Investment Advisor.

I have read several of these contracts that referred clients have brought into me and the wording on these contracts is unbelievable. It is my opinion that there is absolutely NO WAY a lay person, at least 95% of sophisticated investors, and a minimum of 85% of insurance agents/stock brokers could comprehend the verbiage of these contracts. In my opinion, they are an abomination and sale of a majority of these contracts should be halted as soon as possible.

Thank you for your consideration.

Cherie Brown, CFP

Financial Advisor
Certified Financial Planning Professional
Wachovia Securities