Subject: File No. S7-14-08
From: Lawrence P Miller, Jr
Affiliation: CLU, ChFC, CSA, CRFA - Insurance Broker 43 years

October 14, 2008

I believe that indexed annuities should be regulated "as if" they were securities products, primarily for the sake of uniformity and additional oversight. Both the recruiting techniques for new brokers and agents and the marketing systems used to the public seem to imply that the brokers and agents are qualified to make comparisons with other regulated products.

I did sell a very large amount of indexed annuities between late 2001 and early 2004, and was very disappointed when I learned that the "fine print" not disclosed by the trainers of the particular company I used did not allow access to funds the way the marketing folks had implied. The "Statements of (mis)Understanding" used do not make it absolutely clear as to the limitations on liquidity. Fortunately, we were able to discover this before many of our clients actually needed the funds, and have been annuitizing those contracts into other investment products more suitable for their needs.