Subject: File No. S7-14-08
From: John T Cumming, CFP
Affiliation: Series 24/7/63 Registered Rep

October 21, 2008

I strongly support this proposed rule. The investing public does not understand the risks associated with indexed annuities. We see this repeatedly when prospective of clients come to us seeking to understand their investments. They clearly do not understand the extensive holding periods required with indexed annuities and the very high penalties for early withdrawal from an indexed annuity.

I trust that you are aware that various insurance organizations seeking to oppose this proposed rule have sent e-mails to their constituents asking them to submit comments to you. I received one of these requests, but when I checked the response address bar they provided I observed that my response would first go to them before it was forwarded to you. This would allow them to modify my comments or to remove my response so that you would not receive it. Therefore, you need to carefully consider the source of all comments that you receive as they may not truly represent all the comments that you were intended to receive by the respondents.

I personally applaud your attempts to protect the public from unscrupulous insurance agents who are selling investment products without the necessary disclosures required of registered representatives.