November 14, 2008

Subject: File No. S7-14-08

People, I am a Certified Financial Planner and a Registered Investment Advisor in California. I am a member of the Financial Planning Association and I strongly support the proposed rule for the following reasons.

-Indexed annuity products are incredibly complex to describe.

-Sales people often stress the positives without discussing the negatives. This is common.

-Older potential purchasers are often taken advantage of by stressing the "safeness" of these products without disclosing clearly the negatives.

-Insurance agents often stress insurance products like indexed annuities as a simple all-in-one retirement planning solution without showing clients the overall complexity of the problem and the various options/variables that should be considered.

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Gary L. Orkin, CFP