Subject: File No. S7-14-08
From: John B Marshall, Mr.

September 5, 2008

For over ten years I have helped families protect their retirement savings from losses in the stock and bond markets by using Indexed Annuities and Indexed Life Insurance products. I have been Series 6 and 63 licensed and never even offered a market risk based product in order to protect my clients from market risks. Indexed annuities and Indexed Life insurance products have been designed to give people the opportunity to participate in market linked growth without the downside risks.

Millions and millions of dollars have been lost in retirement accounts of Americans who have been put into stocks, mutual funds, bond funds and other stock broker offerings. These are the types of investments that have earned the primary focus of SEC regulatory attention.

Are there insurance agents who have either failed to explain the details of each annuity product offered or sold? Yes. Every industry has this minority. For this reason, strict suitability requirements by the insurance carriers have focused on this concern over the years.

The proposed regulation of indexed annuities would have the effect of exposing more retirees and preretirees to the risk based products mentioned above and cause financial hardship for clients and insurance professionals alike.

Our industry helps people to be able to rely on the safety of their money, and the incomes it can provide.

I respectfully ask that you do not implement the proposed regulations and instead work with insurance carriers to focus more on suitability training.