Subject: File No. S7-14-08
From: Scott F. Goldman, CFP® RFC. CFS. CSA®.CEP®
Affiliation: Waterstone Financial Group, Planning Dynamics, Inc

November 13, 2008

• My name is Scott Goldman, CFP and a member of the FPA with 25 years in the business. I want you to adopt and approve the proposed rules for regulation and oversight for the index annuity business
   
• I have had to many clients come to my office with horror stories that makes me so angry that insurance agents can abuse this product without any oversight or regulation. I had a client who is 80 years of age invested $1,000,000 into 10 different Allianz indexed annuity and had no clue to how the product worked or was not aware of the steep surrender charges to unwind. To make matters worse the insurance agent has a record of misrepresentation and wrong doing and yet the insurance carrier still allowed this person to go out and sell this product.
   
  
  • here are my reasons for approval of proposed regulation:
     
  • the rule is a reasonable and balanced approach to enhancing state enforcement efforts
     
  • the vulnerable aging population needs additional protection from aggressive sales agents
     
  • consumers are often mislead regarding the benefits of an indexed annuity
     
  • liquidity risks, surrender charges, and other suitability factors are not always clearly disclosed or understood
     
  • not all states have adopted suitability standards for annuity sales, nor do most insurance commissioners have adequate enforcement resources available
     
  • some agents misrepresent themselves as offering a single retirement solution when in fact retirement planning is generally a complex planning process

  Scott F. Goldman, CFP® RFC. CFS. CSA®.CEP®
  Waterstone Financial Group
  Planning Dynamics, Inc