Subject: File No. S7-14-08
From: David H Horning
Affiliation: Owner Horning's Acct and Tax Service

August 28, 2008

In reference to SEC 151a proposal I am totally amazed that you would even suggest that Indexed Annuities be added to the list of Securities Products. First you ague that the product is not a security when it is best for you and now that the product is popular you want control of it.

First: The seniors out here are not near as stupid as you make us out to be.

Second: If you have to word a proposal to be vague enough to cover almost anything in order to encompass fixed index annuities then you don't believe this is really a security.

Third: With all of the Securities that are being sold now you cannot keep up with the violations and abuse that is happening with large firms and independant agents around the country. These are the real problems you need to focus on. I inactivated my securities license last year because I do not feel the a variable product is in the best interest to most seniors. Neither do most of them and yet they get talked into these products and loose thousands and tens of thousands of dollars in there investments. These are areas you need to focus on. If the seniors did not feel that fixed index annuities were in there best interest they would not be requesting them.

I have been in the financial consulting business for over 30 years and in the insurance and securities for 8 years.
I work with seniors on a daily basis and this proposed ruling is not in there best interest and they don't like it.

Fourth: This proposed ruling is going to result in a great deal of bad feelings against SEC and will backfire in its face and result in a great deal of expense court costs for what looks like a regulation that does nothing more than increase the power of the SEC for the benefit of the SEC and not the Public.

I implore you to re-evaluate the benefits vs the costs to the public investors that this ruling will cause.

The ruling slaps the State Insurance Commissioners in the face by stating that the states cannot handle the compliance of monitoring Fixed index Annuities.

Last time I checked Socialism was not the political system we were trying to achieve in this country.

Thank you for your time in this matter

Sincerely,

David H. Horning