Subject: File No. S7-14-08
From: Kenneth S Chait

October 27, 2008

Dear SEC:

The whole reason for regulating the "securities industry" is to make sure that brokers sell securities products fairly, openly, honestly, because after all a security always has the "risk of loss."

Equity Indexed Insurance products don't possess such risk of loss through market decline. The insurance company assumes the risk for a profit margin. Regulating Index Products as a security will add unnecessary regulation and requirements to an industry that is already adequately regulated at the state level. I am all for increasing the disclosure requirements for annuity and life sales, especially the Index Products so they will be sold fairly and honestly to the public, but requiring registration is just going too far.

A bank offers a CD and assumes interest rate risk. They invest their profits and depositors capital and guarantee the depositor fixed interest and time on their CD with a guarantee of principal. Should we also call a CD a security? Isn't the bank also buying bonds and other securities just like the insurance companies?

Rather than cause a regulatory hardship on the insurance industry in these trying times it would be better to pressure the Insurance Industry to make better and more complete disclosure for the sales of index products.

Are we really sure this whole thing is not "politically motivated"? Don't we owe the customer the best, most creative and innovative products for which index products have become known? You would be hurting the consumer ultimately and they are always "number one."

Thanks for your consideration.

Kenneth S. Chait
Security Insurance and Financial Services, Inc.