Subject: File No. S7-14-08
From: Adrian Zangirolami

September 3, 2008

It is absolutely ridiculous to try to make Fixed Index Annuities into securities. They are not securities but annuities. It would be comparable to require banks to consider CD's as securities..in fact the FIA's are very similar to CD's, with the difference that they offer tax deferral and better interests and, they are sold by insurance companies instead of banks.
I know that the brokers are sore because they are losing securities sales to the FIA's. But that it is only their fault, because if they cared about their senior customers they would not sell stocks to them, that could lose them lots of money, but they would introduce them to FIA's. The brokers could sell FIA's if they wish, but they do not like to do it because is not as remunerative as the stocks are.
At the end, the proposed rule is nothing more than a money grab dictated by greed, trying to shore up their losses to another market.
Brokers should stop and analyze the needs of the client based on the age of the client, instead of just being product pushers based solely on the commission they are going to make.
There is something of unethical in setting up the retirement funds of a 75 year old client entirely in mutual funds and stocks, that could potentially cause the customer to lose it all.