Subject: File No. S7-14-08

November 3, 2008

This proposal is a bad proposal. Indexed annuities are not securities. They are a fixed product and an insurance product, not subject to principal loss during market fluctuation.

This proposal would limit competition as agents would be forced to deal with just one broker dealer as opposed to being able to shop the free market of insurance companies and choose the best products for their clients, from various providers. The broker dealer would also decide how much should be paid to the producing agent thus adding an additional layer of unnecessary bureaucracy and cost.

The SEC wants more power and money neither of which are warranted in this case. Fixed Index Annuities are fixed products and don't need additional layers of cost or encumbrance.

Feel free to contact me,
Bob McManus