Subject: File No. S7-14-08
From: Terry L Johnson
Affiliation: Insurance Agent

September 8, 2008

I would like to comment on the proposed rule change. I am an insurance agent and sell fixed indexed annuities. My clients like them and have no complaints. These products are already regulated by each state. There is no doubt they have been abused by dishonest agents but that is no different than all the risk advisors who are abusing the current sec rules for selling mutual funds and stocks. This law change will do nothing to protect consumers but rather impose a burdon on many honest insurance agents like myself and possibly put them out of business. Many agents like myself do not want to be branded as those who specialize in a risk type product such as a mutual fund or stock. It is evident that a fixed indexed annuity does not have that kind of risk involved. Please consider all those honest agents who have structured their business toward safety and would need to totally revamp their business should this law pass. To make this product a security is not the answer just as the current laws governing mutual funds and stocks has not eliminated bad investors. Seems each state needs to adopt better suitibility requirements which has greatly improved in the last year. Seems the sec is stepping in at a time when the states have already stepped to the plate. I propose that the sec give each state the opportunity to clean up the bad agents. Thanks for the opportunity to comment on this rule change.