Subject: File No. S7-14-08

July 14, 2008

It has come to my attention that you are considering requiring a series 6 or 7 registration in order to sell equity indexed annuities and equity indexed life insurance.
It seems to me that you should be more considered with oversight on the brokers that are currently registered.  It is amazing how many elderly people that I have talked to have all or most of their money in aggressive stock.  I have talked to elderly people who have lost over half of their life savings in the stock market.  Of course, I am not allowed to advise them about moving this money into an annuity that would conserve their money for their retirement.  There also appears to be little oversight on how often the brokers move the money around.
Certainly, annuity and life products being sold should meet the needs for the clients.  More oversight would insure that this would happen.  Most of the companies that I sell for have reduced penalties as well as the length of their annuity contracts.  Buy turning these products over to brokers, you will have hurt the people that you are attempting to protect.  They will no longer have access to products that protect their savings while providing the possibility of large growth of their savings.
Brokers can already sell these products, but most do not.  Why?  Could it be that they cannot increase their income by moving the money around?
Karl Sipe, Agent