Subject: File No. S7-14-08
From: Reg Kolodi, M.B.A.

September 12, 2008

I strongly oppose the proposed SEC regulation because an Indexed Annuity is a product where most of the principal(minus surrender charges) is generally guaranteed by the issuing Insurance Co. and therefore there is an assurance given by the Insurance Co. that the client will get to keep most of their principal and interest in their Annuity even if the market moves down, except for early withdrawals and surrender charges.
So,how does a product which rarely loses most of its value, except for early surrender charges suddenly become a security?
Why would the SEC want to take away the opportunity for thousands of clients to make a decent return on their money(even if it is not fully liquid some of the time), when a lot of their investments in the stock market are losing most of their value? Major brokerage houses are seeing their clients leave in droves and flocking to safer products like Annuities. See what happened to Lehman Brothers this week.
Major Banks and Investment houses are collapsing but you rarely hear an Insurance Co. collapse.
Also, the amount of Bureaucracy and red tape going to be involved in this ridiculous decision is going to prevent a lot of Insurance Agents from actually helping their clients, since they now have to focus more of their valuable time on achieving more licences and record keeping. Also, if they refuse or are unable to get these new licenses the real losers are going to be the consumers as there might be only limited venues for them to access these products.

Insurance Agents have to already undergo rigourous training as well as do continuing education and ethics courses every year to renew their licences.
Hope the SEC will come to an informed and rational decision on this issue.