November 14, 2008

Subject: File No. S7-14-08

The rule is reasonable and a good approach to enhancing state enforcement efforts. A large part of the "older" generation needs help in dealing with aggressive sales agents who push their product often without making the prospective client aware of surrender charges, liquidity risk and penalties. Consumers need protection from these practices.

Annuities are complex and consumers often misunderstand or are misled regarding their benefits.

I am a member of the FPA and have been in business for 30+ years. I fully support SEC oversight of indexed annuity sales in addition to state oversight by insurance commissioners. At this point in time and considering the current status of the economy added oversight can only be viewed as a positive.

Thank you for your efforts.

D. Randolph Waesche, CFP
President
Resource Management Inc