Subject: File No. S7-14-08
From: Michael G Rogan
Affiliation: President, Rogan and Associates, Inc. Financial Planners

July 21, 2008

As a dually licensed (securities and insurance) 22+ year veteran of the financial securities industry, I applaud this proposal. Abuses in the sale of equity-indexed annuities are the norm, not the exception, and the pain caused to the "investor" - usually a senior citizen - is substantial.

As someone who focuses on an wholistic financial planning approach, I have never found any circumstance where the typical indexed annuity could ever be the best solution. Nearly always, better choices exist with comparable rates of return and far less punitive sales surrender penalties.

In West-Central Florida, the indexed annuities are the product of choice at the free lunch/dinner seminars which often target retirees, and the sales pitch nearly always utilizes scare tactics and sales pressure.

There is little doubt in my mind that securities regulation of these products would dramatically (and nearly instantly after adoption of the rule) decrease their sales. In addition, the promises of "13% guaranteed returns" and claims that the agents are "never paid a comission while the products have no fees" would stop.

For the sake of our investors, please enact this rule. The insurance industry has shown no interest in enforcement. Also, please note, this is not competitive sour grapes. I am fully licensed to sell these products and as owner of my own securities broker-dealer, completely able to sell them. I do, however, have a conscience, which is why no one employed by my firm ever has or ever will sell them.

Thank you.

Sincerely,

Michael Rogan
President
Rogan and Associates, Inc.