Subject: File No. S7-14-08
From: Kevin ODonoghue
Affiliation: Insurance Agent

July 8, 2008

I am an Independent Insuarance agent in Naples, Florida and I am tired of all the bad press over Indexed Annuites / Fixed Indexed Annuities. I hold lunch seminars to attract new clients, thats how I make a living. My seminar material has been approved, and i make an ok living. I am not rich, I just do ok. Every one of my clients understand what they purchase inside and out before they purchase it. Usaually 3-4 meetings have taken place before a sale is made. In return, I have a book of very happy clients,and they understand what they have. I constantly read articles highlighting DO NOT ATTEND FINANCIAL SEMINARS THAT SELL ANNUITIES...ABOUT HOW AGENTS TAKE ADVANTAGE OF SENIORS, AND HOW THEY ARE LOOSING MONEY WITH HIGH SURRENDER CHARGES.WHAT IS IT WITH ALL THE BAD PRESS...

First of all seminars are just a form of marketing for new clientel, since when is this a crime, and what right do you have to bad mouth this form of marketing.

Secondly, the so called pushey salesman of these annuities, who sell the wrong annuities for a clients specific needs, should loose thier license, and should be regulated by the insurance company and the state. Which they do a great job in doing so. Seniors are not stupid,
they know what thier needs are, they have been investing for decades. I do not know of many instances were I sold an Indexed Annuity in the first meeting. It has always have taken me 3-4 meetings of 2-3 hours each meeting. So where are you getting your information from. It is totally false After going over state approved brochures,suitability forms, and a long list of questions that they have answered with me, you can bet they know what they have bought.

Thirdly - Everything that I have read in all the bad press, usually the SEC is involved with this press I have been reading. Their claims are always very generic, not specific in any way, their are many types of indexed annuities, short term 1-5 years, 7-10 year, long term with bonus incentives...All of them protect thier principal, most of them lock in and protect their gains each year, and the long term bonus annuites which offer a large bonus incentive in a trade for longer policy periods. this is no secret BONUS MONEY USUALLY = INCOME ONLY EACH YEAR, USUALLY UP TO 10% A YEAR UP TO 100% WITH OPTIONS THEN TO CHOOSE A VARIETY OF INCOME OPTIONS. THIS IS SIMPLY ALL LAID OUT IN THE CUSTOMER BROCHURE, WHICH ALREADY HAS BEEN STATE APPROVED. Has the SEC ever seen the brochure, there is no mis representation or misleading seniors.
I think over time their may be a few seniors, that had a change in their life which in turn results in a long term indexed annuity may no longer fit like a glove like it may have before, this is the reason to offer short term and long term options to your potenetial clients. JUST LOOK AT ALL THE MONEY THAT HAS BEEN LOST BY SENIORS, IN STOCKS, BONDS, MUTUAL FUNDS OVER THE PAST 50 OR MORE YEARS. DEVASTATING SENIORS PORTFOLIO'S, BUT THAT IS OK, JUST BECAUSE YOU HANDED THEM A 50 PAGE OR MORE PRESPECTUS TO READ. YOUR TRYING TO TELL ME THEY READ A 50 PAGE PROSPECTUS AND NOT A 10 PAGE, LARGE PRINT COLOR BROCHURE THAT THE STATE HAS ALREADY APPROVED.

I THINK YOUR TIME SHOULD BE ELIMINATING BROKERAGE HOUSE FRAUD AND EQUITY SALES TACTICS WHICH HAS DEVASTATED SENIORS RETIREMENT PORTFOLIO'S FOR MANY DECADES.

AGAIN, JUST ANOTHER WAY THE GOVERMENT IS WASTING TAX PAYERS MONEY TRYING TO LINE THEIR OWN POCKETS AND REALLY HAS THEIR INTERESTS AT HEART NOT THE SENIORS/ RETIREE'S OF TODAY OR TOMORROW.