Subject: File No. S7-14-08
From: Mark Glass

September 8, 2008

Good Afternoon:

I believe that leaving Index Annuities under regulation by the individual state Insurance departments is by far the better choice in having oversight in these products. Are there some challenges that could be improved? Yes. But I think they can better be addressed in the current regulation environment. Index annuities by nature should not be classified as securities since the client's principal is secure, unlike securities. I have always done a thorough job in explaining the purpose of Index Annuities and going over the suitability of the product with my clients. Yes, there are some agents who are not thorough enough with their clients in explaining index annuities just as there are with brokers in securities. I believe the best way to deal with this would be possibly some additional educational requirements under state Insurance departments but not re-classifying index annuities as securities. Please don't allow a knee-jerk reaction to something that can better be handled in other ways.
Thank You,
Mark Glass