Subject: File No. S7-14-08
From: Robert R O'Blennis, JD
Affiliation: Chief Compliance Officer, The Retirement Planning Group

August 25, 2008

As a former lawyer and current financial advisor, I am uniquely qualified to comment on this proposed rule.

I do not sell annuities. Never have and never will. I do, however, have clients and routinely meet prospective clients who own annuituies. My experience, without exception, is that these folks have no idea what they have purchased. They have no idea of the terms they have agreed to. And the salesman which sold them often was deceptive during the sales process.

Regulation of these types of investments is critically needed. I wholeheartedly support the adoption of this rule.

The sales techniques by the groups that peddle these investments are often abusive and deceptive. These contracts are sold as investments - thus it makes sense that the SEC exercise some control over the market.

It is critical that the SEC begins to act with regard to the sales of annuities in general. Demographics of retirees shows that we can expect huge numbers of americans coming into control of their retirement savings. It is terribly important to clamp down on the deceptive practices employed by the annuity industry so as to protect these people.

Feel free to contact me for further thoughts. 913-498-8898.

Robert O'Blennis, JD
Chief Compliance Officer
The Retirement Planning Group