Subject: File No. S7-14-08
From: Rick Abend

October 22, 2008

I am a financial advisor and have nearly 40 years of financial experience from starting businesses, consulting , and personal financial management. In recent years we have seen many new regulations designed to protect the consumer. Unfortunately, it seems that not much has changed in the real world. Licensing doesn't keep agents from selling the wrong things to consumers. This proposed regulation to control the sale of fixed index annuities will not protect the consumer. This product itself protects the consumer and the Insurance companies have done a good job of putting training and required notifications in place to help the consumer make a good choice. Licensed professionals aren't supposed to be selling risky investments to older people..but what just happened. We have millions of people seeing their accounts decline dramatically without much hope of recovery because of their advanced age. The fixed index annuity provides protection from this type of event from happening. At this time many people want to move their monies to this type of safe vehicle and I believe that the securities companies want to regulate this product so they can cash in since they will be losing a lot of revenue because people are leaving the stock market. Additional licensing will only ultimately cost the consumer more and not add any additional protection.