November 17, 2008

Subject: File No. S7-14-08

This email is being forward to you from Mark Srofe, CFP registered rep CRD #1758736. It was written by Charles D Vaughan Branch Manger Crowncapital Securities LLC. I agree with the email, the SEC needs to be allowed co-oversight of indexed annuity sales. Consumers are often mislead regarding the benefits of indexed annuities. The rule is a reasonable and offers a balanced approach to enhancing state enforcement. Mark Srofe CFP

Dear Sir

My name is Charles D Vaughan I am a FPA member and also a Registered Rep. CRD# 453724, also I carry a Insurance License from the State of Ohio.

I would like to comment on the rule that would allow for SEC oversight of indexed annuity sales in addition to state oversight by insurance commissioners. I think the SEC oversight is long over due and should be finalized and passed quickly. My experience with misleading and aggressive sales tactics in this area is overwhelming. The insurance agents in our area put themselves out as planners with credentials. They consistently target the elderly and financially uniformed to push high commission products but of course they have only a license to sell insurance and offer little in the balanced approach financial planning needs. The products themselves may have a place in the market place. However, I have seen many individuals who have been sold an unsuitable equity index annuity. One in particular was unaware that the averaging method selected by the agent could produce zero return. This person had been a CD investor at a bank all his life. He went to a "Senior" seminar and was basically hoodwinked into putting over half of his life savings into the product. Our vulnerable aging population needs additional protection from aggressive insurance sales agents. Consumers can be easily mislead regarding the financial planning benefits of an indexed annuity. This particular person feels the insurance agent misrepresented the index annuity as a replacement solution for CD investing. When in fact with the complexities of the retirement planning process the insurance agent was not adequately prepared to address them and was seemingly looking to place assets for the commission.

Our industry needs to take a stand and quickly regarding the oversight by the SEC of index annuity sales. The consumer needs this easy additional protection from aggressive sales agents.

Charles D Vaughan, CFP