Subject: File No. S7-14-08
From: Brian D Todd

September 2, 2008

As a former Registered Representative and current Insurance Producer my professional opinion is as follows:
The securities regulation will add little benefit to consumer protection.

Rational: Unlike a Variable Annuity, a Fixed Index Annuity purchaser will not lose any principal if the market were to have negative returns. The annuity interest crediting method for an FIA protects the owner against loss due to drops in the index. Therefore, by definition FIAs are not a securities product.

One of the main reasons that I did NOT renew my securities license is because an FIA is in most cases the more suitable product for people who are attempting to protect their retirement nest egg.

With this said I ask that the SEC reconsider categorizing Fixed Index Annuities as a securities product and allow the State Insurance Departments to continue regulating this industry. They have already done an awesome job in putting suitability programs in place that would protect consumers and prevent unsuitability offenses by producers.

Please allow the DOI to continue with the obvious aggressive efforts in regulating through programs such as the NAIC Annuity Disclosure Model.

Thank You,
Brian Todd
Insurance License # 346687