Subject: File No. S7-14-08
From: Jay Bugg, CLU, ChFC, LLIF
Affiliation: Sr. VP Life of The Southwest

July 9, 2008

I was very disappointed that the SEC would attempt to take jurisdiction of an insurance product i.e. indexed annuities. This clearly demonstrates a lack of understanding on the SEC's part as to how indexed annuities are designed. These are insurance products in which the insurance company takes the risk, not the customer, therefore meeting the most significant test of the Safe Harbor Rule.
I protest this proposed ruling and find it very offensive to current law and precedent.