Subject: Proposed Index Products Superision

July 9, 2008

TO WHOM IT MAY CONCERN: I have followed with interest the recent proposal made by the SEC to transfer index annuities (probably to be followed by index UL's) under the authority of the SEC. Having been a licensed insurance agent for 50+ years, as well as a licensed Series 7 & 63 broker from 1985 to 2005, I have a few comments for you to consider. The regulation of the insurance industry by the individual states has proven quite satisfactory. In fact, if you consider losses created by fraud or theft incurred in each industry, you would find that the losses created by insurance representative are pennies on the dollar compared to losses created by SEC regulated brokers. Maybe we should consider transferring the authority to the states to regulate the industry. Beginning in October, 2003, I had the first of four major surgeries in a period of thirty months. Because of this, I transferred my business to another broke. The prohibitive cost of maintaining my brokerage license (over $8,000 annually for licenses,E&O insurance and other fees) made it impractical for me to maintain my license. Now to get it back, I must go through all of the tests to sell product. I am working 20 to 35 hours per week. Because I was able to maintain my insurance license at a reasonable fee, I am still able to sell to my client and referral base to supplement my income. You may check my U 4 record if you like, you will find no regulatory or client grievances. The same applies to my insurance record. Quite frankly, I probably could do as good a job for my clients as most brokers, but because of the dictatorial attitude of the SEC, I am prohibited from doing so. As with almost everything directed by the Federal Government, ie: Homeland Security, EPA, etc., the more each aagency gets, the more dictatorial and less efficient they become. I am appalled to think that the SEC could do better than the collective 50 state agencies in regulating an outstanding industry.