Subject: File No. S7-14-08
From: David Lynch

November 13, 2008

To Whom It May Concern:

I am a member of the FPA. I am also a member of NAIFA and the SFSP. I am in favor of the proposed regulation of indexed annuities. I have had many clients and prospects who have purchased them from other agents. None of them have ever been able to tell me correctly what the benefits were. They were all surprised to find out what they were actually getting. Some were surprised at how long the surrender period was and how onerous the charges were. By and large they are sold by agents who also do not appear to fully understand the products they are selling. They are rarely Registered Representatives and rarely CFP’s, CLU, or ChFC’s.

I believe that the opportunity for financial loss caused by inappropriate sales is too great not to fall under the additional scrutiny that other securities transactions are subject to.

Thank you

David Lynch, CLU,ChFC,CFP,CASL