November 14, 2008

Subject: File No. S7-14-08

Gentlemen,

I am a Certified Financial Planner and a Certified Senior Advisor. I hold a Series 7 License and I am a Licensed Securities Principle. I have been practicing financial planning for over twenty six years. I do comprehensive financial, tax, and estate planning for my clients. A significant portion of my business involves securities.

The very idea of requiring a securities license for the sale of indexed annuities is absurd, as it purports to extend the authority of a regulatory agency into an area where it has no practice. Indexed annuities do not involve securities and do not subject owners to security risks.

Having witnessed extremely bad marketing and promotional efforts regarding the sale of indexed annuities, I am fully cognizant of the need for better regulation, however, it should be done by the insurance industry whose products are involved. Fixed income products have no place in the jurisdiction of the SEC, FINRA, or any other securities related agency.

I trust that intelligent rationale will prevail, and that power reaching will have no place in this decision.

Your consideration is appreciated.

Harold J. Rogers, CFP, CSA
President
Retirement Services