Subject: File No. S7-14-08
From: Don N Cameron

September 2, 2008

I stongly disagree with the proposed action for the following reasons:
1.) Basics- These products provide a Guarantee of Principal and minumum interest. The first thing we learned in Securities Licensing was that a Security product has no guarantee.
2.) Fixed Annuities are built to pay an interest rate determined by and insurance company base largely on the performance of their Bond portfolio, a security. Yet there was no attempt to regulate this produce. Indexed annuities are built on a Fixed Annuity Chasis.
3)The financial strength of the Indexed annuity companies could be affected as in the aftermath of regulation you will have a massive reduction in sales force. Sales for each of these companies will decline which could afftect future earinings and reserves.
4) All of my clients understand they are not investing in the market. The index is only a method to determine their interest rate which is just a variation of the fixed annuity mentioned in #2.