December 3, 2008

Subject: File No. S7-14-08

My name is Monte C. Ferguson and I am an active member of FPA and I support the proposed rule for SEC oversight of equity indexed annuities. I am a CFP and ChFC with S6,7,26,63,65- L&H Ann, P&C licenses acting in an OSJ capacity. I have over 13 years of experience in both the career agency and independent channels.

My biggest concern as I work with advisors is a lack of transparency as well as misrepresentation of guarantees which we all know are only guaranteed to the financial strength of the underlying insurance companies. It is apparent with current solvency issues with many otherwise “stable, solid, sound” insurance companies that this is not something to take very lightly. Additionally, we all know that most of the assets headed into these products are coming from pure equity positions which requires a license to sell and therefore should require a license to make a recommendation to move them to another product.

I am available to discuss this further at your request.

Monte C. Ferguson