November 13, 2008

Subject: File No. S7-14-08

I am a Certified Financial Planner and member of the FPA, and want to express my strong support for the rule that would provide for SEC oversight of indexed annuity sales. As a financial planner for over two decades, I have felt a deep sense of frustration in recent years by what I see as the not-so-benign neglect by the SEC of its regulatory role in protecting consumers from potentially and actually harmful actions by people selling financial products.

I recently had a conversation with an individual whose husband had been sold an indexed annuity two years ago. Although this past year's losses by the relevant stock index meant no gains had accrued to this annuity, the annuity did have a no-loss provision that resulted in annuity principle remaining the same as it had been a year earlier. To me, this result is what a customer should have been led to expect under these circumstances. Nonetheless, the sales person who had sold them this annuity was now pitching a switch to another company's annuity product, a product that did not have variable rates of return, thus seeming to guarantee an annual return to invested principle. Outrageous! This is the insurance equivalent of churning in a brokerage account! Consumers need to be protected from this kind of activity, and the SEC is the proper authority for oversight.

Richard D. Kipp
Lifetime Financial Planning