November 17, 2008

Subject: File No S7-14-08

I am a Registered Investment Advisor in the state of Connecticut and a member of FPA and NAPFA. I support the proposed rule that would allow for SEC oversight of Equity Indexed Annuity sales.

I have seen abusive sales tactics regarding this product. In one case, a married elderly couple were sold 5 indexed annuities by the same Allianz agent in a one year period. These were in addition to several other annuity contracts sold to them by this agent, placing all of their investable assets (both qualified and Non-qualified) in annuities with 10 year surrender periods.

Stringent regulation and oversight should be adopted to help protect the public from overly aggressive sales agents who may not have the best interest of the clients in mind. Liquidity risks, surrender charges, and other suitability factors are not always clearly disclosed or understood. Some agents misrepresent themselves as offering a single retirement solution, when in fact retirement planning is generally a complex planning process and diversified portfolio holdings are often the best solution.

This proposed rule is a reasonable and balanced approach to enhancing state enforcement efforts. Please adopt it.

Tom Arconti, CFP®
Principal, Arconti Financial Advisors, LLC

Thomas J. Arconti, CFP®
certified financial planner TM
Arconti Financial Advisors, LLC