Subject: File No. S7-14-08
From: Robert E Collins

September 3, 2008

I believe that moving Fixed Indexed Annuities to the oversight of Securities Regulators, would only make obtaining this type of product unnecessarily complicated and restrictive for a significant number of consumers. Many purchasers of these products have made a conscious decision to purchase a lower risk over-the-counter product, rather than to exposure themselves to more complicated factors inherent in dealing with a registered representative. Therefore, they prefer the safe habor of buying insurance products to meet certain retirement needs. Making FIA's a security would only intimidate many consumers and unnecessarily cloud their perception of such products.

Moreover, Insurance Regulators and Securities Regulators alike have long recognized the separation of Insurance Products and Securities as one measure of protection afforded the consumer. Insurance in its most basic form is simply a way of protecting the lives and lifestyles of the buying public. FIA'a include guarantees of premium and in many cases, rates of return which squarely meet the characteristics and definition of insurance. FIA's are safe money instruments, not securities. They do not include the type of risk associated with Variable Life Products and should not be viewed or treated as such.

If FIA's receive the security tag, the consumer will lose.

One final note: This entire debate was born out of "Special Interest", only securities broker-dealers would benefit. This whole thing has been trumped up to give securities broker-dealers an unfair advantage. It has nothing to do with protecting the customer. State Insurance Regulators have been doing a fine job of that, for the last 75 years or more. I hope someone takes this comment seriously.