Subject: File No. S7-14-08
From: Brian J Sohovich

October 21, 2008

I am strongly for anyone selling index annuities to be required to get their Series 7 license for a few important reasons. First, an index annuity is a complex product that is has a foundation based on stock or bond related indexes therefore being licenses would enable the agent to better understand their product. Secondly, if someone believes an index annuity is appropriate for certain client situations then what they are saying is that stocks, mutual funds, variable annuities or any other product is not appropriate for the client. If that is the case, a Series 7 would help them understand the positives and negatives of all those investment products so they could understand the difference between an index annuity and those above mentioned investment choices.
In summary, I believe anyone selling an index annuity should be required to get their Series 7.