Subject: File No. S7-14-08
From: Peter L Krause

September 2, 2008

This comment is in response to the SEC's desire to treat fixed index annuities in the same manner as stocks and bonds by requiring the same investment oversight.

This type of savings vehicle is nothing like owning a stock or bond. It is actually much more similar to owning a structured CD, with the exception that it is backed by an insurance company's financial strength and not the FDIC.

This type of insurance product (because it is backed by the strength of the insurance company that issues it) should be subject to regulations appropriate to an insurance product to insure the consumer gets a fair product at a fair price. That should be the aim of any improvements in this category.

Peter Krause