Subject: File No. S7-14-08
From: Allison J Brown, CPA

September 3, 2008

I am strongly opposed to the proposed rule change which would require indexed annuities to be regulated by the SEC.

I am a CPA and a University of Chicago MBA. I would have no problems attaining whatever licenses would be required should the rule pass, so that is not the basis for my opposition. I feel the SEC has no place in regulating indexed annuities.

Indexed annuities are not securities. Unlike securities, the investments are safe from loss. Indexed annuities are already highly regulated by state insurance departments.

The SEC has its hands full trying to regulate actual securities. I have seen way too many clients mishandled by "regulated" agents and have seen many retirees' funds put at risk when they can absolutely not afford to take risks. The SEC needs to work on fixing the problems in its own house before it adds another category of investments to oversee.