Subject: File No. S7-14-08
From: Romina A Huffman

September 8, 2008

Hello, I am a licensed Insurance Agent in the State of Ohio. I have been working with the Retirement Community for almost 11 years. During that time because of the availabiltiy of Fixed Indexed Annuities, My clients did not see the plummet of their accounts like many of their friends did that had their money directly in the stock market. This type of account is very important during retirement years in providing protection from downside risk.

Fixed Indexed Annuities, like traditional declared rate fixed annuities, guarantee a minimum interest crediting rate and provide the opportunity to earn interest credits in excess of that guarantee.

Both the design and sale of annuities are highly regulated by state insurance departments as are the companies who manufacture and sell them. State Insurance regulations cover, among other things, suitability of insurance agent recommendations regarding annuities, disclosures and advertising, licensing and training, enforcement actions and penalties for noncompliance with sales practices requirements. Since there are already suitability practices that are reviewed by most all annuity carriers of all sales in all states, it would add no meaningful protection over and above what is already being done.

I feel, as do many of my associates, it is obvious why the Sec has proposed this rule. Many people, in order to provide more protection to their accounts, have chosen to take money out of their investments that are directly in the market in the form of mutual funds, stocks, and bonds and put it into an account such as a fixed indexed annuity. By doing this, it has affected the Investment company in regards to reducing the amount of money under management. Fixed Indexed annuities have made such an impact in those companies bottom line that they have decided to propose the above mentioned ruling. I feel they are not proposing anything that is going to protect the consumer, ultimately it is nothing more than a proposal of greed in order to protect their bottom line.