November 13, 2008

Subject: File No. S7-14-08

To Whom It May Concern:

My name is Deanne Stegeman and I’m a member for the Financial Planning Association. I’m also a licensed insurance agent.

I support the proposed ruling to provide for SEC oversight of indexed annuities.

I’ve spent 7 years in the insurance and financial services industry. I’m a CFP® and a registered CPA with the State of Illinois. My experience involves the sale of insurance products, predominately life and health, as well as mutual funds and managed investment accounts.

I’ve run into situations where a client was sold a variable indexed annuity that they clearly didn’t understand and that was clearly not suited to the client’s needs. The most recent was sold by an agent who had his CFP® certification revoked, so he had moved to selling indexed annuities. Had they been under SEC regulation, the revocation of his securities licensing would have stopped him from selling this type of product. The client was in his 70’s at the time and was rolling over his 401(k) plan and was in poor health. He was sold three indexed annuities all with surrender periods beyond his life expectancy (10-12 years). Add to that the duplication of using an annuity for IRA monies as the IRA already provides the tax deferral and participation the market via mutual funds can be obtained without the charges associated with an annuity.

Index annuities are extremely complex, and not standardized. I find I have to take a lot of time to fully understand how they work. The general public, especially the elderly, in my opinion don’t understand what they are being sold.

I deal with required compliance on a regular basis, and at times I feel that there is overkill in the system, but in this instance, I’m for regulation to help stop abuses I’m seeing in the marketplace.

Sincerely,

Deanne Stegeman

Deanne Stegeman, agent, CFPÒ, CPA
COUNTRY® Insurance & Financial Services