Subject: File No. S7-14-08
From: Laurance E. Gill

September 11, 2008

I am opposed to the SEC regulating indexed annuities because:
1. The Insurance Commissioners are doing a very good job regulating insurance products which the insurance company, not the consumer, takes the risk on.
2. The SEC regulates products known as securities on which the consumer takes the risk. That is not indexed annuities, which are insurance products.
3. The SEC has its hands full in this economy regulating products on which the consumer takes the risk. And, the SEC apparently does not do as good a job regulating what it is responsible for as the insurance commissioners do. Examples: Enron, Bear Stearns, Lehman and the rest of the companies that are about to go down the tubes. The SEC should direct its efforts to helping solve the problems of the economy in what it now regulates, not take on added responsibilities.
4. You are not pulling the wool over the eyes of all the people. The SEC wants the money and power that will accompany putting indexed annuities under its control. That is not in the best interest of the consumer, or the good insurance agents who protect their clients.
5. The consumer will pay more fees, like with variable annuities, if the SEC takes over indexed annuities. The SEC will not be protecting the consumer any better than they are now protected with indexed annuities. The consumer will actually be harmed by the SEC attempting to regulate products they apparently don't understand which is obvious because the SEC thinks indexed annuities are securities not insurance products. The indexed annuities are insurance products and the insurance commissioners do a better job than the SEC does with the products it regulates. Evidenced by the small number of insuance companies facing failure as compared to the Wall Street failures that have occurred and facing failure.
6. The SEC needs to clean up its own house before venturing out into products it doesn't understand.