November 14, 2008

Subject: Equity-Indexed Annuity Rule s7-14-08

My name is Nathan Sealey I have been a broker and insurance agent for over ten years. I am a member of the Financial Planning Association of Michigan, I am a Certified Financial Planner, A Chartered Life underwriter, a Chartered Financial Consultant, a Certified Advisor for Senior Living, and a Securities Branch manager.

I applaud the Sec’s judgment that will require Equity Index Annuities to become a security, but most recently learned that you are thinking of withdrawing that ruling, That would be a terrible mistake. In the last ten years as an advisor and Supervisor of other representatives business I have I have seen and dealt with more than my share of unsuitable, and misleading sales of these products by insurance agents. I support the proposed rule, the rule is a reasonable and has a balanced approach to enhancing state enforcement efforts.

There is increased pressure on our vulnerable aging population who need additional protection from aggressive sales agents

Consumers are more often mislead regarding the benefits of an indexed annuity, their liquidity risks, surrender charges, and other suitability factors are not always clearly disclosed or understood or explained. 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 the time to participate in this important issue!

Thank you again for your trust, business, and referrals.

Nathan D. Sealey CFP, ChFC, CLU, CASL