November 13, 2008

Subject: File No. S7-14-08

I support a rule that would allow for SEC oversight of indexed annuity sales in addition to state oversight by insurance commissioners. Having been in the financial services business over 25 years, I have personally witnessed what I would classify as abusive sales practices and unreasonable claims by insurance companies and their agents. There are a lot of good companies and good agents that do not practice such tactics, but there are certainly those that do that give us all a bad name.

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Chuck

J. Charles (Chuck) Dunham, CFP®, CRPC®
First Financial Group, Inc.