Subject: File No. S7-14-08
From: Thomas L Ratigan

July 11, 2008

I strongly disagree with the proposed change that will require fixed index annuities to be regulated by the SEC. This is an insurance product with guarantees of principle and interest. It does not fit the definition of a security because the insured is guaranteed to never lose money over the entire life of the contract. Issues of suitability have already been addressed by the insurance companies and the various states where these products are sold. All the proposed regulation will do is add more cost into the system at the expense of the client. The SEC can't even police the equity markets now. What purpose is served by putting more regulation into an area that is already protected with guarantees and oversite.