November 14, 2008

Subject: in support of proposed Equity-Indexed Annuity Rule s7-14-08

I have been a Certified Financial Planner professional since 1997 and am a member of NAPFA and FPA and am in support of the proposed Equity-Indexed Annuity Rule. I have served on the Board of my local FPA chapter, including as president and have also been a member of the national FPA government relations committee.

I have seen a number of instances of individuals who were previously sold an unsuitable equity indexed annuity by an insurance agent masquerading as a financial advisor. There are numerous problems with current regulation, which is very uneven depending on the state where the client resides.

I believe that the rule is a reasonable and balanced approach to enhancing state enforcement efforts. The vulnerable aging population needs additional protection from aggressive sales agents. Many consumers are often mislead regarding the benefits of an indexed annuity, without understanding the liquidity risks, surrender charges, and other suitability factors which are not always clearly disclosed or understood. Not all states have adopted suitability standards for annuity sales, nor do most insurance commissioners have adequate enforcement resources available.

Thank you for considering my comments.

Suzanne C. Low, JD, CFP®
Director, Florida Operations
suzanne@lassuswherley.com

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Lassus Wherley