November 13, 2008

Subject: Indexed Annuities s7-14-08

I support SEC oversight of the sale of Indexed Annuities. The sales track being used is “the best of both worlds, all of the up of the stock market and none of the downside risk”. That is investment related marketing and should be treated as all other registered investments and held to the same standards. People are being misled as to how the product actually works. A lot of that is due to a lack of training, education, and oversight by a governing body other than the financial institution selling the products and the State Insurance Commissioner’s office. Since the product is an insurance product the State Insurance Commissioners should have jurisdiction over the insurance aspects of the product but not over the investment aspects and since it is being presented as an investment product it should require the same standards as other investment related products. It is being sold like a Variable Annuity without the risk. VA’s fall under both the SEC and State’s Insurance Commissioner’s offices and so should this product.

Noel K. Edwards, CFP