November 13, 2008

Subject: I support SEC oversight of equity indexed annuities s7-14-08

To Whom it may concern,

I have been a financial advisor for over 25 years. I have been a CFP Practitioner for the last 16+ years. For over 20 years, I was series 7 registered, and licensed to sell insurance products in Illinois and other states. I also served as the Annuity Due Diligence Director for a regional Broker/Dealer, Mesirow Financial. For the last 5+ years, I have been running a Fee-Only practice. I am a member of the FPA and of NAPFA. I wholeheartedly support the current rule regarding the sale of indexed annuities.

While serving as Annuity Due Diligence Director, I did not allow the sale of equity indexed annuities by our firm’s representatives. While I trusted our sales force, I knew that it could be too easy to misuse or sell the products to unsuited clients.

There are many horror stories throughout the industry, and often I have seen clients disillusioned with all advisors, because of the “bad apples” selling equity indexed annuities in inappropriate situations.

I support the current rule:

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 Please consider the matter, and leave the rule in place. I support the rule as a means of helping to curb abusive sales practices, particularly aggressive and misleading sales tactics targeting the elderly. Please do not succumb to thousands of insurance agents who don’t want to be subject to the more rigorous standards that the rule so rightly requires.

Sincerely,

Tom

Thomas H. Zimmerman, CFP®
Zimmerman Wealth Management, LLC