Subject: File No. S7-14-08
From: Jackie Vlachos

October 29, 2008

I am opposed to rule 151A, file number S7-14-08 because this type of annuity is a guaranteed insurance contract which means a person cannot loose any of the deposit or interest credited to the contract no matter what the declining market indexes do.
If you can have SAFETY, GUARANTEED LIFETIME INCOME, The POTENTIAL TO EARN ADDITIONAL INTEREST OVER AND ABOVE THE FIXED OR GUARANTEED INTEREST RATE WITHOUT THE LOSSES OF A DECLINING MARKET how can this be a bad investment choice. The stock market makes NO SUCH GUARANTEES and MANY SENIORS OR SOON TO BE SENIORS HAVE SEEN THEIR Account values lose considerable amounts of retirement funds that they will probably NEVER be able to recoup during their expected life period.
The proposed transfer to a security is NOT in OUR BEST INTEREST. The only reason this is being considered is because of some marketing abuses by some agents, which is true no matter what product is being offered, life, health,annuities,securities, mutual funds, stocks and bonds, and yes even C.D's offered by local banks and brokerage houses.
Please do not incorporate this insurance product under the SEC it would be another regulatory injustice that we cannot afford. Us Seniors need this type of Insurance Product and as long as it is discussed properly,and disclosed properly it should be left as an Insurance Product governed by the state insurance departments.