Subject: File No. S7-14-08
From: Yoshihiro Mizuochi

July 11, 2008

I OPPOSED RULE 151A THAT EQUITY-INDEXED ANNUITIES WILL BE TREATED AS SECURITIES NOT AS AN INSURANCE.

BECAUSE I BELIEVED 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.

INDEXED ANNUITIES OFFER CONSUMER IMPORTANT PROTECTION, NAMELY 1)THE GUARANTEE OF PREMIUM PAID.
2)GUARANTEE OF INTEREST CREDITED.

INDEXED ANNUITIES PROVIDE UNDERLING INTEREST GUARANTEE REGULATED BY THE STATE LAW.

WE ARE LOOKING FOR A POSITIVE RESPONSE. THANK YOU