Subject: File No. S7-14-08
From: James J Frazier
Affiliation: Registered Rep, former PITTSBURGH NAIFA Board Member

August 11, 2008

RE Indexed Annuities

In my 31 years of selling annuities, I have never seen more greed and lack of proper disclosure with any product. Agents and brokers, especially those selling Indexed Products through Banks, are not adequately trained or educated to service this product. Let alone market it to the public. Most often this product sale, is totally commision driven.

Few agents fully understand the complexaties of these products. My experience with the Life Insurance industry over the years rings loud and clear here " When the Agent Commision and Surrender Charge, exceeds 8% and the contract surrender period exceeds 7 years then the product usually is a SHAM"

Most of these products have 9, 10, 11 percent agent level commisions with surrender charges as high as 15%. To me permitting this product to be governed by NIAC, which more often than not is influenced by NAIFA and the PAC's for the Industry, is just uncontionable.

Indexed Annuities are not the problem HOWEVER Sadly it is the greed of the Carriers and Banks selling them that is the problem.

SEC jurisdiction is most certainly avocated here.

James J. Frazier
Pittsburgh PA