Subject: File No. S7-14-08
From: C. C. Bahr, M.S.

October 28, 2008

I am a second generation licensed insurance financial services professional serving a wide variety of individuals, from Doctors to Business Owners to Police Officers.

I am amazed that 151(a) is even being considered when it is obvious the SEC has been mediocre, if not grossly negiligent in their mangement of securities in recent times, and they now want to add additional products are currently and emphatically regulated by each State to federal regulation that has proven to be inept and less than effective.

Indexed Annuities, whether equity linked or fixed are simply NOT SECURITIES. By your own definition, a Security is where the investor assumes risk for the performance of the investment. Equity Linked and Fixed Annuities provide an insured protection that indemnifies no loss of principal to the investor. Therefore, the investor has no risk its all been transferred to the isnruacne company. Broker/Dealers and their licensees can dream up any concotion of an investment they want with no oversight (as evidenced by the current collapse of several wirehouses).

I have found that many currently security-licensed professionals dont know what fixed index annuities and index life insurance are, not to mention how they work, often because these are captive security sales people that want to churn the investments, maintain annual maintance fees, and other costs that are unnessessary and unwanted by many people. They fear the products are superior in suitability for many of our baby boomers, seniors and that RMD's will have an adverse impact on their business. In other words, it appears quite suspect that this is a ploy by the SEC and FINRA to use 151(a) to eliminate competition, which is just un-American.

One client in my office put it terms that most of us can appreciate:" I was tired of paying that guy at Lehman to lose my money".

If you truly want to look out for the well being of Americans, leave this product and its methodology of being reviewed, acturial tested, scrutinized and fixed in place when it comes to market.