Subject: File No. S7-14-08
From: gary kenoff
Affiliation: bba.i., cec. sma (bachelors degree thesis Insurance)

September 3, 2008

I am an Insurance Agent, and have been for the past 40+ years. Having been very successful in the financial planning fields, I take personal offense at your efforts to transfer the sales requirement and function, to the Securities industry, and it's own rules and regulations.

Over the years, I have lost substantial sums of money because of irresponsible "registered representatives", with little help or remedy from your Commission. I even testified for the FBI in stock fraud cases, and the end result was nothing returned as a result of these frauds.
To think that your Commission will in any way benefit the annuity insurance industry is, in my opinion, ludicrous.

Imagine what would have been the case if Bear,Stearns Co,had administered and sold these annuities. What kind of a Federal bailout would have been in place.

Annuities are backed by State Insurance Guaranty Funds, and who provides these funds?....the Insurance Industry, not the SEC. The insurance industry has bailed out the few annuity companies (Financial Benefit Life, Equity Funding,
and others without a single penny lost to annuitants or annuity holders. What would happen should the SEC and Federal Gov. get involved......10 cents on the dollar, if you're lucky

Fixed annuities are valuable products that contain no "down-side" risk. They guarantee payments for life's important events, most of all retirement funds. They were developed by Insurance Companies, who administer them and are subject to very strict regulation under various State Laws. (McCarran Act, Paul v.Virginia,etc).....

As a degree graduate, spending 5 1/2 years studying insurance, financial planning,etc., I resent that your Commission believes that some Registered Representative ( who takes a 6 week "crash" course, is more qualified to sell this product. Please do not approve this proposal.