Subject: File No. S7-14-08
From: Kathleen M O'Donnell
Affiliation: CEO Odonnell Estate Plan Services

September 9, 2008

Your proposed rule will do little except add more intrusive bureaucracy in the name of "consumer protection". Many states have already adopted the NAIC Annuity Disclosure Model Regulation and major index annuity carriers have mandated the use of a disclosure statement or certificate describing all important terms and conditions of the carriers conduct. Also, indexed annuities already offer consumers real protection against investment risk. It is important to disclose information to consumers. Consumers need to be protected. They already are, much more than ever before.

Please do not hurt our industry with this intrusive government regulation that is nothing more than politically correct and will serve to greaty hurt the very people it is supposed to protect by adding more costs, adding more regulation, and making it much harder to do business. Insurance industry protections and compliance standards are very protective of consumers. All your proposed rule change will do is raise costs and make the free market much less free. Please Back Off.

Please do not pass this new rule.

Sincerely,

Kathleen M. O'Donnell