Subject: File No. S7-14-08
From: Liane Abrams
Affiliation: MS

October 20, 2008

The SEC is proposing converting fixed indexed annuities into a security for marketing and sales purposes.

Currently these products are registered as annuity products regulated by the state department of insurance.

These products provide the consumer with annual yields from 0 to 10% depending upon the market performance. You get 100% of the SP 500 gain up to 10%. If the SP 500 goes down the consumer gets nothing during the year and if the SP 500 rises the consumer gets 100% of the gain up to 10%. Simple enough.

Securities firms have been losing consumer dollars to the annuity industry because of the safety features associated with annuities. In fact the indexed annuity business has quadrupled during the last 5 years probably because of the protection afforded by annuities.

Laughably the SEC is now asking for permission to regulate thse products. The SEC feels they are in a better position to regulate in that are more familiar with consumer protection issues.

Ironically, one could point to the SEC's failure to regulate their current turf, as a prmiary reason for the current market woes.

If the SEC were to prevail and take over regulation of the indexed annuity industry, thousands of jobs would be lost due to increased regulation and oversight demanded by the SEC. Furthermore, consumer access to these valuable products would diminish.

Finally, let me state that one of the healthiest sectors in our economy is the annuity industry in that most of the annuity companies continue to operate without distruption. The same could not be said of the brokerage or banking industry.

Why mess with the one industry that is working?

Please ask the SEC to stop pursuing their efforts to regulate the indexed annuity industry and ask them and put an end to SEC proposed ruling 151A.