November 13, 2008

Subject: Comments on File No. S7-14-08

I have been a financial planner since 1968, licensed for both insurance and securities.

I would urge you to treat Equity-Indexed Annuities as securities and subject them to Federal regulation.

I believe that uniform regulation is necessary to protect the older investors who are often preyed upon by aggressive, under-regulated annuity sales agents. The states are not providing adequate protection and they do not have adequate resources to enforce any regulations that they might have. Most contracts are complex, expensive and not understood by the purchasers.

Thank you,

Len Coris
President
Watermill Financial Group