Subject: IN FAVOR -SEC Release No. 33-8933, File No. S7-14-08

August 28, 2008

Sirs:

I am a NAIFA member, regarding the above action. I am IN FAVOR of your proposed action. Even if a representative is scrupulously clean while making the product disclosure for an Equity Indexed Annuity, it is almost impossible for the consumer to differed between market exposure and general account protection. Additionally, companies are required by their own fiduciary responsibility to all company clients to protect and backstop these annuities from matching the market in performance. It is akin to putting metal-flake paint on a tractor and calling it a race car. It is simply not in the contemplated nature of an insurance company general account to match any equity marketplace.

I am concerned because media pundits, perhaps not experts in my profession, use the practices and performance of scoundrels to paint quality registered reps with an unflattering brush.

Dennis Michael Traynor, CLU, MSFS, CLTC, CASL