Subject: File No. S7-14-08
From: William H Schneider

September 8, 2008

By any standard fixed index annuities do not meet the SEC's own definition of a security, and the current requirements for suitability, compliance, and disclosure exceed the norm for all other insurance. And what of fixed index universal life...does the SEC want to regulate that product ,also? Imposing another level of regulation will do nothing to curtail the excesses of a few. While well intentioned, it only will create more forms, disclosure,and compliance hoops to jump through. Did the SEC's oversight of Rite-Aid, Tyco,and Enron have any significant impact on curtailing illegal and unethical behavior once the principals decided to go down that road? The net result of more regulation is simply a more convoluted and confusing informational exchange for our clients. It will not stop the few bad apples in our business. This is one product that is regulated to death already. It is an insurance product by any definition. Leave it at that.