Subject: File No. S7-14-08
From: John A Russell
Affiliation: Investment Advisor Representative / Financial Planner

September 9, 2008

I am opposed to the proposed rule

I understand the need to protect the public and to see that those providing financial products, whether they be securities or insurance products. However Indexed Annuities are not securities and are regulated by state insurance departments as they should be that said. The states
Over the last few years have already addressed the mentioned issues and suitability requirements.

I appreciate the effort to protect consumers and I think we all security licensed / registered or not all need to love our clients and do what is right

However I understand well the difference between insurance products and securities products, indexed annuities are no more securities than indexed mortgage loans and should continue to be regulated by the states insurance commissioners / Departments

Respectfully, John A. Russell