Subject: File No. S7-14-08
From: Michael Frumkin

October 19, 2008

Indexed annuities provide guarantees to my clients and do not need to be regulated by the SEC. This is a blatant attempt by the securities industry, in particular stock brokerage firms, to hijack the insurance business. Based on recent events, more time should be spent regulating stock brokers and less spent regulating insurance agents. Not a single one of my clients has lost anything during the recent market free fall.