November 13, 2008

Subject: File No. S7-14-08

SEC:

My name is Zane Torgrude. I am a licensed Financial Planner and a member of the Financial Planning Association. I have been in the financial services business for over 25 years. I am a fee based financial planner which means I receive a fee for planning services and a fee or commission for investments or insurance products that are purchased by my clients. I am supportive of this rule as proposed and urge it to be adopted. I have found too many cases where an indexed annuity is recommended to people without disclosing exactly what it is, how it works and the extent of its surrender charges. I believe in this environment of complex financial information oversight by the SEC is neccessary. Consumers need to be protected from sales tactics that are only product oriented.

Zane

Zane Torgrude, CLU, ChFC, Vice President
M&I Wealth Management