November 14, 2008

Subject: File No. S7-14-08

As a financial planner and licensed insurance agent ( and securities registered rep ) for over 35 years, I support the rule requiring Index annuities to be subject to SEC oversight to help curb abusive sales practices, especially to the elderly. Index annuities are investment products. Those who sell them should be licensed as registered reps and be securities licensed as either Series 6 or Series 7 securities reps. Currently, index annuities are sold by many individuals who either don’t want to be educated in investment sales ( or can’t pass the required test to sell investments ).

Let’s upgrade the sales force and require the education needed to properly serve the American public.

Thank you,

Robert S. Pennartz