Subject: File No. S7-14-08
From: Steven F Black

July 14, 2008

Dear sirs,

I have read of the intent by FINRA to have the status of indexed annuities changed on the basis of the reference to a securities industry index such as the S P 500, etc.

I have long wondered why, and reason that it must be due to a natural tug of war for possession of a marketplace, as well as to protect the self interest of an entity or industry.

Indexed annuities have been a proven safe and useful tool to benefit savers for the portion of funds not needed for the near term.
With no fear of loss and an interesting opportunity for increase reflected by market index conditions, they have become popular when compared with bank CDs or set rate annuities.

Problems such as unsuitable sales have occurred leading to complaints. but those complaints have been greatly exaggerated as to reality. Some suits have been over the supposed "maturity date" of the contract and failure of understanding that this refers only to the latest date where income payout options could be selected, not to a penalty free maturity as in a bank CD. Lawyers bringing such complaints have added "egg on face" to their profession

A recent tabloid type of sloppy documentary maligned the whole industry and concept of indexed annuities in a very negative, one sided and biased way making every legitimate agent out to appear as a pedefile, as far as the audience was concerned.

Placing indexed annuities under broker dealers would drastically reduce the numbers of agents offering them to the public, providing a huge disservice to safety conscious savers.

I see it as a power grab by FINRA after their failure as NASD in obtaining the ability to control these insurance products, and an error by the SEC if it goes forward with the proposed reclassification of a market-loss-free insurance product, to a prospectus and fee ridden security that would be forced into oblivion.

Let the SEC do its job as it has done so well in the past of protecting consumer's from investment fraud and unnecessary loss, and of protecting risk averse savers' rights of choice in their selection of savings vehicles, not the building of controls and power base of FINRA, and broker dealers.

Let states continue to oversee the insurance products and sales practices including indexed annuities and insurance they've approved for sale in all fifty states.

Respecfully,

Steven F. Black
Insurance agent for the last 12 years.