November 13, 2008

Subject: File No. S7-14-08

I, Sandra K Whipple, CFP(r), MBA, support S7-14-08. It is a fair ruling that benefits the consumer.

I have been in the financial services industry for 10 + years, I am past president of our Middle Tennessee Financial Planning Association and I have an MBA along with my CFP(r) certification.

Indexed annuities are complicated!! If you have seen one, you have seen one! As a series 7 licensed representative I have a responsibility to my clients that the investments that I suggest are suitable to their circumstance. An insurance agent does not necessarily have that same standard. Without that standard there are some agents that take advantage of a trusting public. Unfortunately, many of these trusting folks are citizens in their golden years.

Recently I ran into a contract that the client had been promised a 15% bonus. Yes, there was a bonus, but in order collect that bonus this client could not withdraw any of the money for 10 years. The client is over 65 and this would be an IRA. Required Minimum Distributions will be required from that account before the 10 years are up, so client would loose that bonus, along with the surrender charge owed on current investment. By the way there is liquidity in the current contract.