Subject: Indexed Annuities - Proposed rule 151(A) S7-14-08

October 27, 2008

To Whom It May Concern:

I started my insurance practice in 1997. At that time my concentration was on life insurance. Since then, I have sold a wide variety of insurance products… medicare supplements, cancer insurance, accidental death, disability, health insurance, dental insurance, group plans, etc. But about seven years ago I began to focus my attentions toward helping folks protect the money they had accumulated for their retirement years. I made a conscious decision, and firm commitment, that I did not want to do anything that would place ANY of my clients’ liquid assets at market risk. In my opinion, fixed annuities were the perfect product to accomplish this goal for my clients. Initially, I wrote only traditional fixed annuities. Then I became familiar and comfortable with fixed indexed annuities. I really liked the idea of giving my clients the potential of getting better than average growth, while protecting their “nest egg” against any market losses at the same time. After all, client safety was (and still is) my number one objective.

Because of the “downside market protection” (safety) these products offer, I fail to see how they could ever be considered as securities products. Most of the securities products I am aware of do indeed offer great return (under the right market conditions – certainly not the current market conditions), but also come with a fair amount of risk. But is that not what securities products are supposed to do? Shouldn’t the buyer understand that they are risking their money in exchange for the opportunity for “better” growth? In a nutshell, this is simply NOT the case with a fixed indexed annuity… THERE IS NO MARKET RISK! Incidentally, that is why I have chosen NOT to pursue any type of securities license - I am not willing to subject my clients to risk.

As a Financial Services representative I am proud to offer my clients a product as strong in its design and function as fixed indexed annuities. One which genuinely protects the assets they’ve worked so hard to accumulate – while giving them the potential of a better than average return on their funds. I strongly feel that the life insurance, long term care insurance and fixed annuity products I offer today can work in concert to accomplish this goal for those who have entrusted me to assist them in these areas.

I am of the strong opinion that all fixed annuities (traditional and indexed) are exactly what they were designed to be - insurance products. Because of this, I respectfully ask that you reconsider the proposed rule set before you (151A) which, if passed, would re-classify all fixed indexed annuities as securities products. I believe the consequences of that decision would be adverse and detrimental - not only to individual advisors like myself, but to the Independent Marketing Organizations, the Insurance companies, and ultimately even to our clients, the policy holders.

Sincerely,

Eddie Lane
Kingsport, TN