November 14, 2008

Subject: File No. S7-14-08

I would strongly encourage the SEC to adopt oversight of Equity Indexed Annuities.

These products are quite complex.
* Many different crediting methods.
* Tied to many different equity indexes.
* Dividends are not included.
* Spreads, rate caps and participation rates can all potentially change during the life of a contract.
* Costs embedded into these spreads and caps are not disclosed
* Minimum return can be based on less than 100% of purchase amount.
* Early termination values can be volatile and unpredictable

Taken together it is clear to me the average consumer is highly unlikely to understand what they are buying and need a higher standard of regulation than simple fixed annuities which are the model of simplicity in comparison.

I have a Ph.D., am a certified financial planner and registered investment advisor and I find that even many financial professionals have difficulty understanding exactly how an EIA contract works and its expected return.

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David B. Jacobs, Ph.D., CFP®, NAPFA-RA
Pathfinder Financial Services, LLC