Subject: File No. S7-14-08
From: Joel P Gooch

September 4, 2008

The proposed inclusion of Indexed Annuities as securities will be a big mistake. Fixed annuities are not securities simply because there is no investment involved. Clients can purchase fixed annuites that can be credited by several different interest crediting methods, among which are indexed to the performance of certain security index performances.The money is always 100% principal guaranteed and can not lose money. As with CD's early withdrawal can mean early surrender charges but these are voluntary and not mandatory. All annuities have provisions for withdrawals that are penalty free and are designed to the individual clients needs.The SEC regulates VARIABLE ANNUITIES and they are the biggest cause of lconfusion among senior policyholders. As they CAN LOSE MONEY they should be banned for sale as retirement vehicles. Fixed Indexed Annuities do not, can not, and will not lose money.The very untruthful presentation put on by CNBC that Chairman Cox showed the committee was deeply flawed and shown out of context. For a 65 year old man that purchased a 40,000 annuity to have to sell his house because he had to surrender his annuity early is totally absurd. Obviously he was looking for a handout with his testimony before the TV camera. The State Insurance Dept. do a good job of regulating insurance sales and the SEC should not get involved. We have TOO MUCH government now and do not need more.