November 14, 2008

Subject: File No. S7-14-08

Dear Sirs:

As a Certified Financial Planner (CFP) for over 27 years and a member of the Financial Planning Association or its predecessors for over 31 years, I wanted to comment on the abuses I’ve seen in the indexed annuity markets the past several years. I have seen policies foisted on clients that have withdrawal periods of 10 to 20 years, starting as high as 20%. I have seen policies that have averaged 2% annual returns in up markets. These plans are often marketed as the solution to every retirees investment need by purveyors who have no license or experience with investments. I am not a fan of government regulation but I support the rule that would allow for oversight of indexed annuity sales by the SEC. These instruments need to be put on a level playing field with variable annuities.

Thanks you for considering my comments.

Sincerely,

Lowell R. (Lou) Lemesany
Certified Financial Planner (CFP)
Ameriprise Advisor Services, Inc.