Subject: File No. S7-14-08
From: Craig Miller
Affiliation: Series 7 Registered Rep, 20 years

July 11, 2008

This proposal is lunacy. The securities industry should focus on regulating its own house. The insurance industry offers guarantees and conservative investments which have helped millions adequately save for retirement. Market indices do not affect the principal of Index Annuities, do not have the risk of securities, and should not be classified as such.