Subject: File No. S7-14-08
From: ilana edelstein

July 11, 2008

Indexed annuities have been successful because the nature of the product meets the needs of the saving public. They are NOT a high-risk investment where a consumer can lose his or her principle, in fact they are a risk-adverse savings vehicle.

Indexed annuities offer consumers important protections, namely (1) the guarantee of premiums paid and (2) guarantee of interest credited. They provide underlying interest guarantees required by state law.

There is little difference in the risk to a policyholder for a traditional fixed annuity versus an indexed annuity. Under both forms of annuities, the policyholder is at risk to the insurer's annual interest rate declaration, whether it is an expressed percentage amount or a formula relating to changes in an index.

The sales practices and suitability safeguards needed for index annuities are the same safeguards needed for all life and annuity products. The proper supervision needed for traditional fixed annuities, indexed annuities, and life insurance can be, and is being performed according to state insurance department rules.

The results of the SECs proposed rule WILL NOT be to benefit savers because:

1. It will burden the savers with costs (indexed annuities will then have expenses for filing, regulation, and supervision)

2. It will reduce the number of agents who can offer a product that is beneficial to many savers. Agents who have established long standing, trustworthy and mutually successful relationships with savers (clients).

3. It will be financially catastrophic to many individuals, agents and small businesses.

4 It will give Broker/Dealers the ability to suppress a viable, valuable, and successful form of retirement savings, which has and would continue to provide strong competition to those retirement savings traditionally offered by Broker/Dealers.

5. It will give Broker/Dealers a monopoly...which in the USA is against the law...the Anti-Trust laws should surely not allow this