November 15, 2008

Subject: File No. S7-14-08

I want to go on record as supporting the proposed rule allowing the SEC oversight of indexed annuities.

I have been in the financial services industry over 30 years. In addition to being a CFP/PFS and CFP(r), I am licensed as both an insurance agent and a registered representative. I am an active member of the Financial Planning Association and the American Institute of CPAs. I have served as a chairman of the San Antonio CPA Society, the TSCPA's Relations with IRS and Advanced Estate Planning Committees, and currently serve on the TSCPA's Investment Committee. I own both a CPA firm and a registered investment advisor practice.

Despite the high commissions available, I refuse to participate in the sale of indexed annuities as I consider them an unsuitable product, generally sold by misleading hype to uninformed consumers by unknowledgeable salesman masquerading as financial advisors. It is appalling to hear these agents on weekend radio shows with their one-sided pitches that go unchallenged. It makes me wonder how much worse the pitch is behind closed doors to those not equipped to understand the product.

The current regulations are inadequate from the following perspectives:

a. Consumers are often mislead about these annuities'' benefits and risks
b. Lack of adequate, understandable disclosure about liquidity risks, surrender charges and other suitability factors.
c. Not all states have adopted suitability standards and many commissioners have inadequate enforcement resources available.
d. Agents sometimes misrepresent the product as THE retirement solution whereas retirement planning is usually a complex process.
The rule is a reasonable and balance approached to enhance state efforts and protect our vulnerable aging population from aggressive salesmen. I look forward to its implementation.

Jim Oliver CPA/PFS, CFP®
Jim Oliver & Associates, P.C.
CPAs & Business Advisors