Subject: File No. S7-14-08
From: Ben E McCoy
Affiliation: CLU, ChFC, RHU President McCoy Co.

September 4, 2008

I ask that you reconsider this proposal. The State Insurance Departments are more than adequately handling regulation of Indexed annuities. These products are not securities.

A security has a risk to Principal. Index annuities guarantee Principal. These products are currently used by millions of Americans to help achieve their savings without the inherint risks associated with the stock market, further this rule change would have a devastating effect on many insurance agents as well as many insurance companies specializing in offering Indexed annuities.

Both the design and sale of these products are already highly regulated by state insurance departments as are the companies who manufacture and sell them.

If the proposal is not withdrawn, at the very least the comment period should be extended significantly so that adequate dialoque can take place before subjecting the sale of these products to dual and redundant regulation.