Subject: File No. S7-14-08
From: Irma S Stringer

July 11, 2008

I would like to comment on the proposed rule that will treat Equity-Indexed Annuities as Securities, not insurance. I believe equity-indexed annuities are insurance contracts and not securities. These insurance products should continue to be regulated at the state level and not at a federal government level.

Indexed annuities have been successful because the nature of the product meets the needs of the saving public. PERIOD. They are risk - adverse savings vehicles and not high-risk investment products where a consumer can lose his or her principal Score one for us little guys

Indexed annuities offer consumers important protections, namely: (1) the guarantee of premiums paid and (2) guarantee of interest credited. They provide underlying interest guarantees required by state law.

There is little difference in the risk to a policyholder for a traditional fixed annuity versus an indexed annuity. Under both forms of annuities, the policyholder is at risk to the insurer's annual interest rate declaration, whether it is an expressed percentage amount or a formula relating to changes in an index.

The sales practices and suitability safeguards needed for index annuities are the same safeguards needed for all life and annuity products. The proper supervision needed for traditional fixed annuities, indexed annuities, and life insurance can be, and is being, performed according to state insurance department rules.

The results of the SECs proposed rule will not be to benefit savers but to:
1. Reduce the number of agents who can offer a product that is beneficial to many savers

2. Burden indexed annuities with unneeded additional expenses (for filing, regulation, and supervision), the cost which will be borne by savers

3. Damage financially many individuals, small businesses, and smaller insurance companies and

4 Give Broker/Dealers the ability to suppress a viable, valuable, and successful form of retirement savings which has and would continue to provide strong competition to those retirement savings offerings traditionally made by Broker/Dealers.

It would be in the best interest of Americans to keep things the way they are and allow the little guy at least a chance to be able to save and keep his money for his retirement. Lord knows SS isn't going to be there for them.

Sincerely,
Sue Stringer