November 13, 2008

Subject: File# S7-14-08

How can an insurance agent sell an Indexed annuity, and compare it to an EQUITY Index so that the client understands what he

has purchased?

If the industry does not want SEC oversight then remove the product.That products' performance will react as an Equity and therefore needs to be understood as such.

I believe that the industry created said product for their agents who do not have a series 7 license so they could make more $ for the Carrier and the agent w/o putting the client first.

This issue sounds very much like what the Brokerage houses wanted to do with their brokers becoming "Financial Planners" without oversight nor following the same rules I have to abide.

I vote yes for SEC oversight-better yet eliminate the product as a survey of a few 100 or so owners of the product will show their level of disclosure from their Life Agent.

I may be wrong-but I doubt it very much.

Have a great day,

Steve Cariati, CFP
Albany, NY