November 13, 2008

Subject: File No. S7-14-08

My name is Jim MacKay, I am a Certified Financial Planner and Portfolio Manager for Springfield Trust & Investment Company in Springfield, MO. I am a member of the Financial Planning Association and I support the proposed rule. For the past nine years I have worked in various capacities with insurance agencies, investment management firms, and now with an independent trust company. During that time I have helped thousands of people address financial concerns from the very small to the very complex life-changing events we all face. The moments that strike me as particularly troublesome are those that involve annuities.

In my years of training and experience, I have come to appreciate the value of annuities for particular situations and understand what they can bring to the table. But in my thousands of experiences with people of all types, I have yet to see one person currently owning a variable annuity that I would consider an appropriate candidate for that product. In addition, due to the complex nature of the contract that each annuitant is required to sign, I have yet to experience an annuity owner that understands what they purchased. Two points on that note: 1. The contracts are often sixty pages or more in length. 2. My clients tell me that the annuity salesperson refuses to show them a copy of the contract until one has been signed. How are they to understand what they are purchasing if they can't read it until a contract is signed? Then, when they do get one, it is sixty pages long and full of jargon and explanations of the complexities of the product.

The combination of complicated contracts, overzealous salespeople, and huge commissions have created an unhealthy situation for investors. It is my hope that this message along with the others before and after me will convince those with the power to change, to do just that. The annuity industry, which has gained much of its power and influence at the expense of our country's elderly, are attempting to use that power and influence to benefit further. I'm glad you are in a position to address that and hope that this rule is passed and that change comes soon.

Sincerely,

Jim MacKay, CFP®
Asst. Vice President / Portfolio Manager
Springfield Trust & Investment Company