November 13, 2008

Subject: File No. S7-14-08

To Whom It May Concern:

I am a Certified Financial Planner practitioner who has been licensed with the NASD since 1992. I hold licenses series 6,7,24,31,63 and 65 as well as Life insurance and Health insurance licenses in more than one state. I built my business on fair and ethical practices and have in the past used dinner seminar marketing extensively as a way to meet prospective clients. I have recommended Equity Index Annuities to many people over the years and can see that they are extremely easy to sell to folks for all the wrong reasons; the commissions can be very attractive. The EIA is not a blanket solution for all Americans, nor is it appropriate for everyone. As part of a properly diversified portfolio of investments it may be the right choice, but I see registered individuals as well as insurance agents who use them in an abusive and unscrupulous manner. A case in point is a gentleman that I met here in Chandler who attended a dinner seminar because he was uneasy about his EIA investment. This man was over 70 when he was persuaded to invest the major portion of his investable assets in an EIA that had a high surrender charge schedule that ran into his 90’s!!! This is a typical scenario. Possibly a relatively smaller portion of his assets would have been a good fit for an EIA, but the only reason he owned this annuity was because of the commission to the agent. I do not believe that crooks and scoundrels can be controlled by regulation, but the public need to be protected.

Neil Fisch

Neil Fisch, CERTIFIED FINANCIAL PLANNER Professional