November 13, 2008

Subject: In Support of File No. S7-14-08

To Whom It May Concern:

My name is Dori Ben-David and I am a Certified Financial Planning Practitioner and a member of the Financial Planning Association. I am writing to express my support for proposed rule, File No. S7-14-08.

As a financial planner, I have been dismayed over the years to see how often clients are pressured into buying inappropriate insurance products, especially equity-indexed annuities. Currently, I am working with a new client, age 67, who was pressured into converting her old annuity into a new annuity – told that she would have to pay a tax, if she didn’t (which was false). She was not told about the new surrender charges that were now applied to the new annuity or about the increased annual fees charged to this new annuity. She is now convinced that she was misled into purchasing this annuity.

New regulation must be put into place to help protect vulnerable consumers from aggressive sales agents who are extremely incentivized (with huge commissions) to sell and churn as much as possible.

Thank you for your work in serving and protecting the public,

Dori Ben-David

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Dori Ben-David, CFP®
Ben-David Financial Planning