Subject: File No. S7-14-08
From: Lloyd E. S. Taylor
Affiliation: CEO, Taylor Retirement Resources

September 11, 2008

I am opposed to this change in law primarily due to the FACT that Equity Indexed Annuities are NOT securities. They are insurance products. The public cannot lose money with these products. The insurance companies bear the risks... not the public. They are best regulated at the state level and should remain under the jurisdiction of the state insurance commissioners. The SEC should NOT regulate these kinds of products. With the current meltdowns of such staple companies as Bear Stearns, Lehman Brothers, Fannie Mae, Freddie Mac, and many banks, also under SEC jurisdiction, I am not at all convinced that the SEC can effectively monitor these products any better than the state insurance commissioners. The additional regulatory requirements would most certainly add to the costs of these products and ultimately hurt the consumers. I go back to the main reason for not allowing the SEC to regulate these Indexed Annuities...they are NOT securities. For the SEC to arbitrarily decide they should regulate these products, is tantamount to the Police Chief of Los Angeles suddenly deciding he is going to promote himself to oversee the New York neighborhoods and downtown New York areas as well.
He has no business doing so, and no authority to do so, he just decides he'd like to expand his territory.
I am sure that the reason this law has been introduced is due to the politics of Wall Street losing market share of late, and of course it is about the almighty dollar. Let's be real here. The SEC needs to get busy monitoring those companies and products that legitimately ARE securities and leave these products alone. It is obvious to me and to every other licensed insurance agent selling fixed indexed annuities, that I personally know, that the SEC already apparently has more to oversee than they can effectively do without adding a product that is not an equity to begin with. Based on their track record, I shudder to think what would happen to the senior citizens of our nation if these products come under the jurisdiction of the SEC. No one has ever lost any money due to downturn of the markets with a Fixed Indexed Annuity. The Supreme Court has ruled that these products are not equities nor securities. Local regulation is sufficient. Thank you for the opportunity to make my sentiments heard.
Lloyd E. S. Taylor