Subject: File No. S7-14-08
From: David W Deutsch

October 20, 2008

Dear Sir:
Equity Indexed Annuities are not securities. They have guarantees that stocks, bonds, and mutual funds do not have. They are and should remain regulated by the state insurance departments. In light of how poorly the SEC has done regulating banks and brokerage houses, they should not be involved in regulating these annuities.
I believe the brokerage houses that are in favor of SEC regulation are doing so mainly because they want to get a piece of the commissions that they now don't get.
The state do a much better job of protecting the public from fraud and abuse from sales agents than the SEC. Just look at Lehman Brothers, Merrill Lynch, Morgan Stanley, Goldman Sachs, and the banking industry to see that what I am saying is correct.
Thank you,