Subject: File No. S7-14-08
From: Joe Mullin

July 20, 2008

It is my belief this is something that needs to be done. Many "advisors" (insurance agents) are suggesting to many clients to sell various security products without full knowledge of those products. It then suggested the client purchase a "no loss" indexed annuity. many of these agents have no idea of how the product they are replacing works, nor are they qualified to explain them. Many of them do even carry E O insurance.
Several of the newer products offered as indexed annuities offer 100% participation in the SP with no cap and charge a fee.... sounds like a V.A. to me. if it walks like a duck and quacks like a duck it probably is a duck.
Sounds like we need this rule fast.