Subject: File No. S7-14-08
From: Jay Wilcox

October 29, 2008

The insurance industry has made great strides to have agents do their due diligence by requesting Identity verification, client suitability in great detail and full disclosure. The SEC can't possibly do a better job and in fact would confuse consumers considerably by offering a product that is contractually guaranteed. That would lead consumers to think that all SEC regulated products are guaranteed, as of course, they are not. I have met many individuals that think their mutual funds and stocks are guaranteed because of SIPC. There is already too much confusion for the public. The insurance industry is highly regulated and controlled. Leave the guaranteed products to the insurance companies and the SEC can regulate the unguaranteed markets. Besides, consumer confidence is totally shaken with the catastrophic losses people have incurred as a result of the market declines. It would be a mistake for the SEC to step in now after more than a decade of oversight by the insurance companies. Besides, fixed annuities are regulated by the insurance departments of each state. Is the SEC on a power hungry drive to regulate all markets? This is a proposal that should be shut down vigorously and if the public was aware of what the SEC was trying to do, they would overwhelmingly disagree with the SEC.