September 3, 2008
This draft regulation adds an unnecessary layer of regulation to this insurance product. Indexed products are not securities and are already heavy regulated by state insurance departments. The SEC is rushing this proposal for adoption without appropriate time for minimal consideration by the insurance industry and its regulators. Exaggerated market abuses: please consider the products the SEC regulates now and compare them to the way these FIA are regulated now. The fixed indexed annuity is an insurance product. Any financial product will experience market abuse by a few. These have been corrected and there is no need for the SEC to rush to a wrong decisino based on market abuse stories and fear tactics. We demand more than the unilateral damaging action the SEC is proposing. This needless action will have a profound impact on the insurance industry and is being done without appropriate action on behalf of the SEC.