November 13, 2008

Subject: File No. S7-14-08

I am a Certified Financial Planner licensee and Registered Investment Advisor with 8 years experience working with clients to secure their financial future.

I support your current rule regarding Indexed Annuities. These products, for the most part, are inappropriate for most people. Your rule is the minimum consumer protection we can accept to protect an aging population from commission driven 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

John M. Smith, CFP®