Subject: File No. S7-14-08
From: Linda P Cypres, Ph.D, MBA
Affiliation: Independent insurance agent, and investment advisor representative

September 3, 2008

I would like to request an extension for the comment period as insurance agents have not had enough time to give their input.

Personally I object to this ruling on several grounds. First, indexed annuities are fixed, no risk investments, in which investors have no downside risk whatever, which differentiates them from all securities.

Second, the suitability requirements for annuities provide strict guidelines for appropriateness, and if you were to compare the number of complaints for securities vs annuities you will find that the states strictly enforce these suitability requirements.

Third, the public will be the ones to suffer because seniors in particular need products which give them SAFETY as well as growth potential, which indexed annuities do. Typically stock brokers only recommend variable annuities which have downside risk.

Fourth, this ruling will put thousands of insurance agents either out of business or will greatly impact their profitability, as well as deprive them of being able to offer their clients some upside potential without downside risk. Of course insurance companies will all greatly suffer as their marketing costs skyrocket. So who will be the beneficiaries??

Perhaps the securities brokers will benefit because there will be less competition for customer's dollars. The brokerage firms will benefit by attracting more money. But the public will pay the price.. and for a flimsy
argument which, in my opinion, is misinformed.