Subject: File No. S7-14-08
From: Michael J Kudla, JD
Affiliation: Professor of Economics Buena Vista University

September 2, 2008

This proposed rule is definitely a misinterpretation of what indexed annuities are. Owners of indexed annuities are sharing in the earnings of what insurance companies invest their money in the stock market. If I bought a fixed annuity, I get a fixed amount of earnings whereas with an indexed annuity, my earnings are based on the market which could increase my potential. The insurance company, whether it be a fixed annuity or an indexed annuity is still investing the money in the market. Why shouldn't a client have the privilege of getting more and losing nothing? This ruling would restrict sales and not help in improving the economy. Less money spent, the worse the economy gets.