Subject: File No. S7-14-08
From: Michael W Pioro
Affiliation: CLU, LUTCF

July 10, 2008

The soaring popularity of fixed indexed annuities has caused the SEC to focus on them and for its own purposes to classiy them as securities.

By its own definition of a "security", it seems that there is little that cannot be considered such. Is not a traditional whole life insurance policy a security as defined under 151a?
1. The cash value is linked to the the company's general account which is in fact a bunch of securities.
2. The dividends paid by a participating policy will pay far more than the guaranteed values.

Likewise for the traditional fixed annuity.

The insurance industry is regulated and monitored sufficiently enough to preclude the SEC from adding yet another layer of bureaucratic requirements. When there are problems or sales abuses (which will happen regardless of 151a) let the insurance industry deal with and correct them. Another policeman will do nothing to improve things.

VOTE NO for 151a