November 16, 2008

Subject: File No. S7-14-08

Dear Financial Services colleague,

I want to voice a " no support" comment for 151A.

I am president of an agency that sells all forms of fixed annuities ( as well as other insurance products). I believe we all agree that Fixed Index Annuities are not securities. I am currently registered with a Broker/Dealer and I am securities testing next week. After 27 years in the business ,I see that I would like to broaden my offering to clients. However, the thousands of clients that have purchased FIA products over the years though our agency are quite content with their contract and it’s performance.

After studying the number of sales complaints at the various insurance departments ( we are licensed in 50 states) I am shocked that the case for 151A is based on poor and unsuitable sales practices and oversight. It looks to me that the variable annuity sales practices could use more attention from FINRA. How many older people have been sold variable annuities inappropriately ?How much principal has been lost by those people ?

The attraction of FIAs IS THE INSURANCE ! It should stay that way. I humbly submit that your organization is better served putting it’s energies toward the crisis in regulation and oversight needed in other areas in light of current conditions in financial services.

As a member of NAIFA and NAFA, I believe in our industry playing by the rules and educating professionals and consumers enthusiastically.

I also believe we need to enforce the regulatory framework that has already been created. Maybe we should all work toward those goals 1st ?

Sincerely,

Jeff Warren
President
Markman Group