November 15, 2008

Subject: S7-14-08

I am writing in opposition to the proposed rule.

I am a Chfc, AEP, an independent RIA, and also insurance licensed. This is my 19th year in business and I provide fee based financial plans, fees for money under management using well diversified, passively managed, no load mutual funds, and commissioned insurance products.

In my experience I have seen much more harm to the public through Registered Reps selling poorly designed investment portfolios, overseen by BD’s and regulated by FINRA and the SEC, than by insurance agents selling Fixed Index Annuities. I have had new clients (many of them retirees) come into my office who have suffered losses 40%, 50%, and more. I have not seen any such losses with FIA’s, even when surrendered early.

The insurance industry is vastly improving their oversight and training of agents. Compared to the one page applications for annuities used 15 years ago, today we have numerous suitability forms and customer contacts by insurance company suitability reps to protect consumers from inexperienced and/or unethical agents. I believe consumers will be put at much greater risk if FIA’s are sold by Registered Reps who are no better trained or regulated and may influence consumers to take greater risk through purchasing stocks and stock mutual funds. This is especially true of seniors/retirees who may not have as much time on their side to ride out market downturns, and whose need for income from their retirement savings put them at even greater risk during such times.

I believe it more prudent to bring pressure to bear on the insurance companies to continue to improve their products and the training and oversight of their agents.

Hank Parrott,ChFC
Estate & Financial Strategies, Inc