November 13, 2008

Subject: File No. S7-14-08

To Whomever it may concern:

I am in favor of the Equity Index Annuity rule.

By way of background, I have been a financial advisor licensed in both insurance and securities for 22 years. I am a Investment Advisor Representative and a Certified Financial Planner™ Practitioner. I have worked with over 1,000 individuals and families and have trained 50 financial advisors over the years.

I have often encountered consumers who purchased “investments” that were not well suited for them. The product that I see more often than others is annuities that are sold by non-security licensed individuals. It seems that when an agent has just one product that they can recommend, nearly everyone they see needs to own that product. If the agent was licensed and able to use a wider variety of products, the equity indexed annuity would not be sold nearly as often.

The other issue is with client suitability. I have seen many consumers who are not the appropriate age, or will not be invested long enough for this product to be an appropriate one for their circumstance.

Finally, I have yet to find a consumer, or an agent be able to fully understand and explain all of the nuances of these complicated products. More licensing/oversight would be a good start.

Thank you for this opportunity to share my thoughts,

Ed Moore
Fairfax, Virginia