November 14, 2008

Subject: s7-14-08

I am a long time member of the Financial Planning Association (FPA) and am writing in opposition to the proposed rule allowing SEC oversight of indexed annuity sales. I have held the CFP® designation since 1988 and have been an active member in the FPA since its founding.

The SEC has enough on its plate and should not stray into the regulation of what is clearly a fixed product (and not a security). State insurance regulation is sufficient to handle the various problems that have been cited regarding equity indexed annuity sales since these problems are not distinct from those which arise with regard to the sale of other fixed products.

A. Raymond Benton, CFP®
Member of President's Cabinet
Lincoln Financial Advisors