November 13, 2008

Subject: File No. S7-14-08

a. My name is Joel A. Larsen, CFP, and I am writing in support of the proposed rule. I have almost 20 years experience as a financial planner AND a licensed insurance agent, both within corporate America and as an independent advisor. It is time we moved financial advise away from the “sales model”, which has caused much of the problems we are facing today, and move toward the “advice model”, in which consumers get their advice from a professional, not a salesperson.
b. I believe:
a. the rule is a reasonable and balanced approach to enhancing state enforcement efforts
b. the vulnerable aging population needs additional protection from aggressive sales agents
c. consumers are often mislead regarding the benefits of an indexed annuity
d. liquidity risks, surrender charges, and other suitability factors are not always clearly disclosed or understood
e. not all states have adopted suitability standards for annuity sales, nor do most insurance commissioners have adequate enforcement resources available
f. some agents misrepresent themselves as offering a single retirement solution when in fact retirement planning is generally a complex planning process

If you would like to discuss this with me further, my contact information is listed below.

Joel A. Larsen, CFP