November 17, 2008

Subject: File No. S7-14-08

To: rule-comments@sec.gov

Re: File No S7-14-08

Securities and Exchange Commission:

As a member of the FPA, a Certified Financial Planner and a licensed insurance agent, I am writing to urge you NOT to withdraw the above referenced rule proposal. I am in full support of the Equity-Indexed Annuity Rule.

As a financial advisor I have personally aided clients who have been sold unsuitable equity indexed annuity products. Your proposal provides a reasonable, balanced approach to aiding state enforcement efforts, thus providing additional protection to the vulnerable aging population against aggressive sales agents.

Consumers are too easily misled regarding the benefits of indexed annuities, as the liquidity risks, surrender charges and other suitability factors are often not explained or even disclosed. Some states have not adopted suitability standards for annuity sales, and many insurance commissions do not have adequate enforcement resources available. In addition, agents often misrepresent themselves as offering a single retirement solution when various options are usually available and alternatives are actually more suitable for meeting the consumer’s need.

As a financial professional, I am very pleased with the Commissions measured approach to establishing a dual system of insurance-securities oversight. This proposed rule is a significant step forward in ensuring that those selling indexed annuity products understand the products they are recommending and that consumers are making informed choices about their investments.

I fully support the Proposed Rule 151A.

Sincerely

Jane Watts , CF

P