November 13, 2008

Subject: File No. S7-14-08

I am responding to the above mentioned ruling for additional oversight relating to Indexed annuities, in particular in sales to seniors. I have been involved with Financial planning since 1966, first as the Senior investment officer of a Bank Trust Department, and then as then as a Financial Planner with a Actuarial Benefits and Consulting firm in Massachusetts. In my years of work, the majority of my clients were 50+ years of age. I worked on a fee and commission basis until the last 10 years when I switched fully to the fee only basis when dealing with individuals. Over the years strongly felt the product sales and particularly Insurance products were often driven commission motivated individuals and the companies sponsoring the products. I have been a member of the Financial Planning Association since 1997. Since 1990, I have felt that the number of abuses had leveled off, but that doesn't make it right. I find that too many people are more interested in the sale or are pressured by their supervisors to meet sales targets to be seriously in putting the clients interest first.

I remember after completing my insurance product training at the Actuarial Benefits and Consulting firm which had strongly encouraged putting the clients interests before my own, the first three annuity product materials I received in the mail offered the agent a 15% commission if you sold that product . While rules continued to changed for both the securities and insurance products, the abuses continued. I feel this will be a more serious problem as we have an increasing number of seniors and a larger number of people not properly prepared for retirement.

I feel annuities have place in the proper planning process. There is no one best single solution that fits every case. Planning is a process that takes time and effort to obtain the relevant facts and to build trust with every client. The insurance industry, as does the security industry, has had it struggles and does create new products which can be misunderstood by planners and their clients that could result in disaster in the long run for the client.

I think we have seen the results of poor oversight, lack of adequate knowledge of the product risk and the high levels of greed in our current worldwide financial crisis. I support File No. S7-14-08

Todd Marchant FPA CT