November 13, 2008

Subject: Index annuity rules

To whom it may concern,
I am highly in favor of File No. S7-14-08. As a CFP in California I have encountered three cases where elderly ladies(clients) have been to "free" luncheon meetings to learn about Living Trusts. When contacted for their free consultation they are encouraged to bring in their investment statements to eventually "fund" their Trust. The statements are then converted to the index annuity with surrender periods over 15 years. One client over 85 had no idea she had such an investment and was shocked to learn of the restrictions when she wanted access to her funds to enjoy a vacation with a grandchild. Another senior wanted to use the funds to purchase a home while her primary residence was waiting to close, a huge penalty would have resulted. People today selling these index annuities to the elderly are unethical at best.
I hope the regulators will give mind to the unsuspecting and curb this investment to the elderly. Regards,

Edna M Burr

Sterling Financial Services, Inc.