November 13, 2008

Subject: File No. S7-14-08

I am in favor of having securities regulators oversee index annuities!

I am a member of FPA and a FINRA registered principal with 28 yrs experience

Over the years as a practitioner and supervisor, I have seen these product sold without full disclosure, long surrender charges that were not disclosed and large commissions that the purchaser was unaware were being generated.

Problems with current regulation:
a. the 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 annuity 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 complex planning process
Thanks for the opportunity to be heard.

Eliot

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Planning Pays Off / The Financial Delegation Experience™
Eliot M. Weissberg, CFP®, CFS
The Investors Center, Inc.
Financial & Insurance Services
Raymond James Financial Services, Inc., Member: FINRA/SIPC