Subject: File No. S7-14-08
From: Johnny D. Christensen
Affiliation: Certified Senior Advisor (CSA)

September 3, 2008

I think for the majority of the insurance agents out there, more disclosure would be needed. But to add a Prospectus to every sale of a Fixed Index Annuity would send out the wrong message. These are not securities, they are fixed annuities with returns based on the performance of an Index. They cannot lose money from the performance of the market, thus they are not securities. What you have are two things affecting this decision.

1) Agents putting clients money into a product that has longer than a 10 year surrender period, to get more commission. Although those kinds of products are not availble in Utah.

2) Brokers are losing there clients money to good Fixed Index Annuities because there sick of losing money, and when they do, their broker never calls.

I have been in this business for 18 years and I have never had a complaint against a Fixed Index Annuity. I understand they can be misleading to some that were never educated on how they work. But the SEC proposed decision to regulate them would be a very wrong decision.