Subject: File No. S7-14-08
From: Joseph T Donnantuoni
Affiliation: Broker and Agent

October 17, 2008

I am a former NASD examiner. I transact business in index annuities at times. What I noticed is extreme non-uniformity in the initial lock -in of the index point close for new contracts, and the non-uniformity of index calculation method guidelines for clarity. In addition, there is a hieghtened unfair form of competition between insurance companies regarding replacement activity. If a replacing company provides a fedx acct number or other type of overnight number to use for check transmittal, the delivering insurance company will refuse it and use regular mail for large checks. This is a deliberate inefficiency and a further attempt to interfere with the client decision to buy without having any suitability information for such delays. Markets shouldn't work that way. Lastly, insurance agents will not be able to show that they review or understand properly approved research on stock and bond markets and therefore do not seem to be in a position to select and recommend which strategy or strategies to use. There is no doubt that supervision is needed. I don't know if it fits the SEC definitions of a security. In any event, having a mere S65 won't cut it.