Subject: File No. S7-14-08
From: Chris Tornio

October 29, 2008

This proposed legislation by the SEC is simply not needed, and potentially damaging to the efficient system of bringing Fixed-Indexed Annuities to the general public.

The current system whereby classified as an insurance product, is a correct and prudent method of establishing FIA control and marketing. Unlike investment products which are and should be regulated by the SEC, there is NO market downside risk with a FIA. This has been proven with exceptional clarity in recent months, and is consistent within the concept of risk management inherent in an insurance product. Additionally, state insurance regulations mandate considerable "suitability" parameters which must be adhered to in the sale of FIAs. Licensed insurance agents must also complete regular training regarding the sale and applicability of such products to the general public, and these proceedures are constantly monitored, revised and adapted to insure the safe and consistent marketing of FIAs. Reclassification and consequent regulation by the SEC is simply not neccessary. It would also potentially diminish the availability of these products from the main street consumer, for which they are a very viable means of safely managing assets, in a means consistent with the other risk-averted products handled by the insurance community. Chris Tornio / Noah Insurance Group