Subject: "File Number S7-14-08"

July 15, 2008

Re: Proposed requirements on sales of index annuities by licensed insurance agents.

After 44 years in the insurance, banking and securities business and seven years of publishing and editing insurance and investment sales magazines I have concluded that increased oversight is required by the federal government in order to assure the proper and ethical treatment of the sales practices of index annuities. My former position as an insurance journalist allowed me access to hundreds of financial professionals. This access provided numerous opportunities to meet, interview and discuss all aspects of insurance products' sales procedures.
Having attended dozens of issuing company and marketing company sales presentations to insurance agents on how to market index annuities there can be no doubt that a complete description of the workings of index annuity products is grossly missing from these presentations. The level of understanding of these products by licensed insurance representatives is totally inadequate. Because of the sophisticated nature and underlying strategies of index annuities the buying public needs to be assured that sales representatives have the knowledge and training to respond to questions and adequately educate them about the risks, costs, advantages and disadvantages inherent to all types of annuity products.
Having been licensed as an insurance agent, licensed as a stock broker and licensed as a securities branch manager, I am familiar with the requirements needed to properly understand and market various security and insurance products. The state insurance requirements that I have met over the years in MN, NJ, NY and FL are wholly inadequate to meet the requirements needed to sell the sophisticated products being introduced today.

Lyle Gary