Subject: File No. S7-14-08
From: Ronald M. Robins
Affiliation: Beacon Financial Advisors, Inc.

November 13, 2008

I am in favor of Federal oversight of equity indexed annuity sales.

I am a member of the FPA. I have been licensed to sell insurance and annuity products for 15 years (as well as securities) I am also an RIA. I am aware of clients who have purchased equity indexed annuities that were totally inappropriate for their situations. However, the unscrupulous agents who sold them were handsomely rewarded by their companies and never brought to punishment for their activities.

I have the following thoughts regarding the proposed rule.

• the rule is a reasonable and balanced approach to enhancing state enforcement efforts
• the vulnerable aging population needs additional protection from aggressive sales agents
• consumers are often mislead regarding the benefits of an indexed annuity
• liquidity risks, surrender charges, and other suitability factors are not always clearly disclosed or understood
• not all states have adopted suitability standards for annity sales, nor do most insurance commissioners have adequate enforcement resources available
• some agents misrepresent themselves as offering a single retirement solution when in fact retirement planning is generally a complex planning process

Thank you,

Ronald M. Robins
Beacon Financial Advisors, Inc.