November 14, 2008

Subject: File No. S7-14-08

Dear Sirs,

I am writing to comment on the proposed rule change to provide federal oversight of the sale and marketing of "indexed annuities". As a CERTIFIED FINANCIAL PLANNER™ practitioner and a member of the financial planning association I would like to strongly urge you to adopt this rule for the betterment of our industry.

In addition to my credentials and securities licenses (7,63,66,24) I am also insurance licensed in several states. While there is nothing inherently wrong with indexed annuities in general, some of the sales practices being used by a minority of agents is bringing disrepute to an entire industry. I have had clients tell me while explaining the benefits of such a policy they purchased that they "can't lose money..." and "get all of the upside of the stock market with no downside". These statements are, of course, ludicrous but it is exactly how many of these contracts are being positioned. Consumers seemingly have no idea about the restrictions, fees and caps associated with these investments.

The insurance commissioners are ill-equipped to deal with the massive scope of how these policies are used and I am reminded of the scandals endured by our industry in the 80's and 90's regarding UL and VUL contracts. It is time for reform that puts the consumer first and provides for reasonable standards for the sale and marketing of these investments. No business ever suffered from too high a standard.

Yours truly,

Garrett R. Morgan, CFP®
CEO / Fountainhead Private Wealth Management