Subject: File No. S7-14-08
From: Max H Snodgrass, Jr.
Affiliation: Agent

September 9, 2008

I strongly oppose this proposed rule. I have sold fixed Index Annuities for the past several years and if this rule is adopted, it would have a traumatic effect on my business and my livelihood since I am not a registered representative nor do I intend to become one. The majority of my clients are either retired or getting close, and they love these products because they do not like to take market risks and I dont like to put them at risk either. None of my clients have ever lost a single dime in these products due to market conditions or fluctuations because they are not in the market. For this reason, the SEC involvement is not necessary. This is just an obvious attempt from the Wall-street firms and brokerages to control and reduce the sale of these products because they are in direct competition with their products such as Mutual Funds and Variable Annuities. These Fixed Index Annuity products are already highly regulated and require several disclosures at the point of sale to protect the consumer. This is clearly a fixed product that gives the consumer growth opportunity with protection from negative market conditions at a time when they clearly want it and need it the most. I believe that SEC involvement will dramatically limit the availability of these products to the consumers who obviously have a need and desire for these products, based on the amount of consumers that purchase them. I believe that the majority of the consumers that have Fixed Index Annuities are quite pleased with their results over the past 12 months (which are predominantly no gains), as opposed to the consumers that have products sold by registered representatives who have LOST money. Maybe the Wall-street firms should consider selling Fixed Index Annuities to their clients instead of trying to take them away from the consumers that want and need them and the agents that sell them.