Subject: File No. S7-14-08
From: Duane A Howe
Affiliation: Insurance agent

July 11, 2008

It is my understanding that the SEC is considering taking the insurance products of "Fixed" Indexed Annuities and treating them as a security product. I was a series 6 registerd rep for many years. Upon seing seniors loose their life savings to the market, I decided that I did not want any more to do with the SEC and securities controls. The development of fixed products today offers people to truly do what they want to do..the opportunity to get a decient return on their money while having the protection of not loosing their money to market down turns.

Registered representatives have a conflict of interest in offering these types of products because of the commissions of money management on securities products Vs single commission long term contracts of fixed annuities.

The public will be harmed if competition is eliminated by the SEC. Fixed Indexed Annuities are not a risk type of investment because the only money that is subject to loss by a negative market is the fixed interest that the person elects to place in the indexed interest options available. Not one cent of the principle is at risk to the market.

Fixed indexed annuities are no more a security then any fixed annuity offered by insurance companies. You will only take away the competition of securities representative who have a very negative attitude in selling this product.