Subject: File No. S7-14-08
From: Thomas m Shamblin

September 3, 2008

I believe the fixed indexed annuities should be considered an insurance product and left to the regulation of the respective State. Making the product a variable security product only plays into the hands of the Broker dealers to take a cut of the available commissions for doing absolutely nothing in terms of the transaction. Regulate it at the State level with additional CE requirments and enforce the law when a few unscrupulous agents take advantage of a client relationship. The local independent agents continue to get the hsort end of the stick as B/D cash in and more costs are downshifted to the local main street businesses trying to make a living and create jobs. How much regulation is enough?