November 18, 2008

Subject: No. S7-14-08

I am opposed to Rule 151A.

My name is R. Douglas Cobb. I am a member of NAFA, I am an Investment Advisor Representative with a 65, 6, & 63 securities license as well as a California Insurance license and a Notary Public. I have been in business for 30 years.

This last quarter I have received many calls from clients thanking me that a portion of their money was safe in a Fixed Index Annuity. Many would be down 30% or more had they not moved their money from other places that were not safe.

Your proposed rule would not help anyone to be more safe as I have counseled many people who were sold variable annuities and told they were safe and “insured.” Many clients whose age and financial status that made the variable annuity a totally inappropriate vehicle for these people. I met with a lady just last week who was convinced that her variable annuity was safe and was earning a guaranteed 6% interest rate. The SEC isn't curbing any abusive sales tatics with variable annuities there is no reason to believe they can police sales on Fixed Annuities any better than the State is doing now.

The above person had invested $170,000 into this variable annuity and the account value is now $103,000. We called the insurance company on speaker phone to have them explain how the 6% guarantee works and now she knows she was mislead and defrauded. This is an area the SEC already is controlling and people are still being taken advantage of.

Adding Fixed Index Annuities to SEC oversight will only complicate the issues and will not provide any additional safety to our clients what so ever.

Vote NO on 151A.

R. Douglas Cobb
Investment Advisor Representative
Cobb Planning Group