November 13, 2008

Subject: File No. S7-14-08 Comment

Re: Support of proposed rule - file no. S7-14-08

My name is Steve Barnes and I'm a member of the Financial Planning Association.

I have been a Financial Planner for over 20 years. I'm a Certified Financial Planner, Chartered Financial Consultant, Accredited Estate Planner and LUTCF Fellow. I have been licensed as an insurance agent since 1986.

The unregulated product, Indexed Annuities, has caused many individuals and families to seek our services to assist them in understanding and exiting these products. One daughter of an elderly parent was "Sold" but not properly advised an Equity Index Annuity (ETF) after consulting an insurance agent. She specifically told the agent several times she needs to keep her mother's assets safe and liquid as she is using principal and interest to cover her mother's care. The agent sold her two Variable Annuities (VA) and two ETF's. She now can only take 10% each year from three of the annuities and one of the ETF's will never get away from the surrender charges. The surrender charge on the other ETF is 12 years. Both ETF's will continue the surrender charges even after her mother's death. With the market down, she has to take less than last year as 10% of the VA's lower value is not enough and she can't take more from the ETF as the surrender charges are over 12%.

Citing a letter from the FPA, I agree with the items below:

* the rule is a reasonable and balanced approach to enhancing state enforcement efforts
* the vulnerable aging population needs additional protection from aggressive sales agents
* consumers are often mislead regarding the benefits of an indexed annuity
* liquidity risks, surrender charges, and other suitability factors are not always clearly disclosed or understood
* not all states have adopted suitability standards for annuity sales, nor do most insurance commissioners have adequate enforcement resources available
* some agents misrepresent themselves as offering a single retirement solution when in fact retirement planning is generally a complex planning process

Thank you for taking time to read this.

--------------------------------------------------------------------------------
Steven A. Barnes, CFP, ChFC, AEP
CERTIFIED FINANCIAL PLANNER
www.BarnesWealth.com