Subject: File No. S7-14-08
From: William A. McKnight, MBA, CFP®
Affiliation: Vice President, Kays Financial Advisory Corporation

July 8, 2008

I agree that the SEC should step in to change the way financial salespeople sell Equity Indexed Annuities.

Selling Indexed Annuities should require that the representative have a Securities License. Simply acquiring an insurance license and enrolling with an insurance company should not qualify anyone to sell these very complex products. Sales practices include comparisons to major market indices such as the Standard and Poor's 500, the Dow and NASDAQ. Additionally, the underlying mechanism to participate in market performance is through the use of stock call options. How many agents or buyers are aware of this?

Marketing companies should have to join or become broker-dealers so that may be overseen and regulated like everyone else in the securities business.

Long surrender charge products of more than seven years should disappear. No client should be forced to lock their money into any investment in order to pay the agent big commissions.

Commissions should be lower on a product that virtually requires no follow up or support by the agents on the client's behalf after the sell.

Indexed Annuity products will have the same suitability standards as Variable Annuity products. They should. In essence they are securities and investment vehicles.