Subject: File No. S7-14-08
From: Christine Carlton

September 4, 2008

The securities regulation will add little benefit to consumer protection. Many state already have adopted NAIC Annuity Disclosure Model regulation and most, if not all, of the major idex annuity carriers have mandated the use of disclosure statement or certificate descibing all important terms and conditions of the annuity contract, including prominent disclosure of surrender charges. Many, if not all major indexed annuity carriers conduct suitability reviews of all sales in all states. Additional suitability required by FINRA would not add any meaningful protection. In addition, annuities are simply not securities, instead they offer protection against investment risk. The DJIA has suffered a decline this year in excess of 20% from October 2007 record, but no one who had a fixed indexed annuitiy suffered any loss. It is not appropriate for an indexed annuity to carry the label of a security....it is afterall, and has been for over 200 years...an insurance product Let's keep it that way.