November 13, 2008

Subject: File No. S7-14-08

Dear Sir/Madam:

I have been both a registered representative and a licensed insurance agent advising clients from my office in Leawood, KS for more than 20 years. We are in the Kansas City metro area. I am a member of the Financial Planners Association (FPA) and I support the proposed equity-indexed annuity rule.

I have marketed indexed annuities to a few of my clients as the situation called for it, so I am not opposed to them at all. They can be the perfect product on occasion.

However, as my awareness of the marketing tactics being employed by insurance agents who have a low understanding of equity markets, I have been appalled. Equity-indexed annuities need to be marketed by people who can explain the upside and the downside. I have talked with senior citizens who have been approached by insurance agents, usually in a seminar setting, and these senior citizens have been completely misled. It is truly difficult to believe the sales pitches they have been given.

Please don’t let a good product be smeared with a bad reputation by greedy insurance agents who have no concept of the risks associated with the product. Marketing Equity-indexed annuities requires at least a moderate working knowledge of the equity markets.

Cordially,

Whitney Westgate

Whitney Westgate
Registered Principal
Windsor Financial Group
Securities and investment advice offered through FSC Securities Corporation, a registered broker dealer and Registered Investment Advisor. Member FINRA and SIPC.