November 13, 2008

Subject: "File No. S7-14-08

I am a CFP, and member of an RIA firm. Also I am an active member of the FPA.

I want to state upfront that I support the proposed rule.

In an age when disclosure and forthright advice is so very necessary, I consider equity indexed annuity sales to be largely unsuitable; especially given the impact of markets on client retirement goals.

Here are the problems with the current regulation:

a.. the new 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 annity 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 much more complex planning process

Please do what should be done to protect consumers!

Sincerely,

Mark
________________________________________________________
Mark Janci
Investment Counselor
Halbert, Hargrove/Russell LLC