Subject: File No. S7-14-08
From: Robert Gellenbeck
Affiliation: Insurance Agent

July 11, 2008

My understanding is that the SEC is considering this action to protect seniors. They truly do need to protect seniors from current Securities Licensed Individuals (SLI's)and the products that they sell.

I sell indexed annuities. They are safe fixed annuities. As opposed to many of the products that SLI"s sell to seniors today.

Example: My mother-in-law went into her bank to make a deposit. The teller saw her balances and sent her over to talk to the resident SLI and in a few minutes he had her putting $10,000 into a bond fund that he told her would yield about 6% per year. He did not tell her that her initial investment amount would fluctuate. One month later she got her first statement showing interest credited but her balance had gone below the $10,000. She got very upset and called us for advice. We went to the bank with her to meet with the SLI only to find he had been transferred across town. We had to have the asst manager of the bank help us unwind the account to save my mother-in-law's sanity. No exaggeration there.

SLI's do not like the fact that indexed annuities are truly supplanting their efforts to sell variable annuities and other securities to seniors. Indexed annuities are safe and much better for most people not just seniors.

Bottom line the current situation is working. Those of us who sell indexed annuities not only are selling a good safe alternative and we are heavily regulated by the companies that we represent.

We are also providing a public service by providing a contrast between our product and securities products that are much more unsafe.

The current system is working and it is working quite well.