November 14, 2008

Subject: File No. S7-14-08

Dear Sir/Madam, I support the proposed rule on the sales of indexed annuities. I am a member of FPA, a Certified Financial Planner and Chartered Life Underwriter and have been in financial planning since 1972. I also have a BS in Mathematics from Eastern Michigan Univ. with a Masters Degree in Educational Administration. I have witnessed abuses in the sales of indexed annuities here in Michigan and through seminar selling. Most agents don’t understand all the moving parts and investment crediting methods in the contracts and therefore aren’t describing the features to clients appropriately. The lack of liquidity resulting in high commissions also are issues. Overall, clients are being mislead and these products need more oversight. Dale Robinson

Dale P. Robinson, CFP, CLU