November 13, 2008

Subject: FILE #S7-14-08 EQUITY INDEXED ANNUITY RULE

SECURITIES AND EXCHANGE COMMISSION:
I AM A MEMBER OF THE FINANCIAL PLANNING ASSOCIATION, AND I SUPPORT THIS PROPOSAL.
I HAVE BEEN A CERTIFIED FINANCIAL PLANNER SINCE 1985, AND AM ALSO LICENSED TO SELL LIFE INSURANCE, ACCIDENT & HEALTH, AND VARIABLE LIFE & VARIABLE ANNUITIES.

EQUITY INDEXED ANNUITY PRODUCTS ARE NOT SIMPLE PRODUCTS TO UNDERSTAND, PARTICULARLY FOR SENIORS. THESE ARE UNSUITABLE FOR THE MAJORITY OF SENIORS.
THERE ARE MANY SALES AGENTS WHO ARE OVERLY AGGRESSIVE WHEN DEALING WITH THE ELDERLY. CONSUMERS ARE MISLED REGARDING THE ADVANTAGES OF INDEX ANNUITIES.

DISADVANTAGES OF THESE PRODUCTS ARE NOT OFTEN DISCLOSED DURING THE SALES PRESENTATION. SURRENDER CHARGES, LIQUIDITY RISKS, AND OTHER FACTORS ARE NOT DISCLOSED OR ARE MISUNDERSTOOD.

RETIREMENT PLANNING IS A COMPLEX ARENA WHICH HAS MANY VARIED AND INTERTWINED SOLUTIONS; IT IS NOT A SINGLE SOLUTION. OVERSIGHT BY SEC AND THE STATE INSURANCE COMMISSIONERS SHOULD BE A NUMBER ONE PRIORITY. THE INTERESTS OF A TIMID AND GULLIBLE PUBLIC MUST BE PROTECTED AT ALL COSTS.


ETHICS SEEM TO GO OUT THE WINDOW WHEN INSURANCE SALESPEOPLE SEE DOLLARS COMING IN.

SINCERELY,
WILLIAM F. KEATS, CFP, EA