Subject: File No. S7-14-08
From: DANIEL GOODMAN

October 16, 2008

When you begin to define indexed annuities as securities you need to know that you will be hurting the very consumers you are now seeking to protect because product dilution will inevitably follow.
Most of the consumers who purchase indexed annuities are seniors desiring safety with a bit extra upside potential.
The moment you begin treating indexed annuities as securities you've changed the nature of what appealed to nearly all of its consumers and that is its safety.
It's kind of like having a lettuce and tomato ham sandwich and now because there's lettuce and tomato it's got to be a salad. The lettuce and tomato being the indexing, that small secondary, albeit important feature, that comes along after safety.
If something talks like a duck, walks like a duck, and looks like a duck -- please don't call it a goose.
This new proposal is not a good idea. The consumers stand to lose much more than anyone else.