November 13, 2008

Subject: File # S7-14-08

I have been a financial service professional for over 34 years. I am a Chartered Life Underwriter and a Certified Financial Planner as well as a Certified Retirement Planning Counselor. I have seen too many instances when my clients have called me after going to a "free meal seminar" and ended up replacing a perfectly good annuity product with an indexed annuity. In all of the cases that I can recall, the person selling the indexed annuity product was NOT a security licensed individual. As a security licensed producer, I have to have total disclosure about everything I do so my Principal can review my every action...even my seminars MUST be completely disclosed including the actual words I use. My knowledge of the insurance industry tells me that none of these precautions are taken by any insurance company licensing the writing agent plus there is no Principal to review what is being said or presented.

I urge the SEC to have these very complicated instruments placed under the watchful eye of an ombudsman like the SEC, since there is NO ONE doing any scrutiny of these products and their presentations by an individual who may not be properly versed in the things that NEED be said when dealing with the public about equity issues. Older citizens merely hear the words: Guaranteed interest rate no loss of principal while investing in the "market". Sounds too good to be true? That's because the agent never discusses the surrender charges or the complicated methods used to determine the "equity yield".

Gene G Stern, CLU, CRPC, CFP®
Retirement and Wealth Planning
Financial Planner Practitioner
Lincoln Financial Advisors, Inc.