Subject: File No. S7-14-08
From: Kris B Lloyd, Sr

September 9, 2008

Annuities are insurance products, and as such are (rightfully) under the jurisdiction of state insurance regulators. They do not meet the definition of securities under the Securities and Exchange Act, and by any common sense interpretation should NOT be considered securities. Variable rate mortgages have rates tied to interest rate indices, but you are not attempting to classify them as securities. Likewise, variable rate CD's are not being regulated as securities. Annuities are CONTRACTS They arer NOT traded on any exchange, public or private. Like CD's, they GUARANTEE return of principal, and some method of accrueing INTEREST Like CD's, the only way a purchaser can lose money is a) they trigger a premature withdrawal penalty or b) the issuer defaults on the contract. Admittedly, there have been some egregious sales tactics used by a FEW agents in selling these products, BUT, the proper forum for addressing this lies withing the STATE regulators.