Subject: File No. S7-14-08
From: Donald W Rizzo, CLU

September 10, 2008

It is important that the individual states maintain regulatory authority over these products. The individual states can better institute the educational, licensing, registration and continuing education requirements. They are also better suited to investigate complaints on a local basis and administer any penalties if necessary. They have done this effectively with respect to viatical settlement products and, with all the publicity given indexed products, will undoubtedly be even better suited and quicker to act in this area.

Any other authority getting involved will only add to the complexity and negate our attempts to educate and simplify for the public, as well as the financial service industry, a product that could be of value to many consumers under the proper circumstances.