Subject: File No. S7-14-08
From: Peter A Kitzerow, CLU, ChFC

November 3, 2008

Fixed Indexed Annuities (FIAs) are excellent products that give consumer guarantees,flexibility, tax-deferral and many other advantages. While FIAs are not for everyone, sales of these innovative products have soared in recent years because they give consumers a unique combination of guaranteed protection and opportunity for higher accumulation than traditional fixed annuities. This is a package of benefits that variable products (already regulated by you) are unable to provide.

The SECs draft regulation (rule 151A) adds an unnecessary layer of securities regulation to this insurance product. FIA products are heavily regulated by state insurance departments. Through the NAIC,state regulators have worked hard over many years to come up with appropriate suitability and disclosure requirements for FIA products. To the credit of state insurance regulators,this work continues today and should not be derailed by the SECs unilateral action.

It seems to this writer that the only reason for the SEC wishing to regulate thses products is to prevent disintermediation of resources from the securities industry to the insurance industry.

The truth of the matter is that I have been selling FIA's to my clients for over ten years. To date, not one of them has lost a red cent through these vehicles. This is a claim which which my mutual fund and variable annuity clients and the securities industry at large can't make.

As a producer who has both insurance and securities licenses, it seems to me that the only justificaiton is to enrich broker dealers and enlarge the juggernaut of government regulation. As you know, currently broker dealers are not compensated for these products.

If you wish to allow them to sell these products it should be under the regulaton of the state insurance departments, because they are insurance products and not the SEC.

In short, this writer believes that you should stick to your knitting.