Subject: File No. S7-14-08
From: Mel Dawson
Affiliation: Simmons First Investor Services, Raymond James Financial Services, Inc.

November 4, 2008

The problem with Equity-Indexed Annuities is not a matter of identifying what type of product they are (fixed annuities with a variable rate of return), but the regulation of them. Locally, we see attendees of the 'seminars' who are told "You don't pay us any commission. The insurance company pays us". Of course, the Insurance Department would not approve that statement, but the insurance agents are unlikely to make that statement in the presence of any regulators.

The advertising materials and invitations have included statements about the agents "expertise" and that the prospects will receive information that their lawyer, accountant and broker will not tell them.

Our Senior citizens deserve to understand how the products work including surrender fees, expenses, rate caps, and the truth about commissions (including the amount of commission). If the Insurance Departments can regulate the products properly and enforce those regulations immediately, then allow the Equity-Indexed Annuities to remain classified as "Fixed Annuities" and allow knowledgeable insurance agents to sell them. If this cannot be done, give the SEC an opportunity to regulate these products. If that means classifiying them as securities, so be it.

When a product fits a client's risk tolerance, goals and objectives, the truth about the product should be sufficient. Deceptive sales practices should not be allowed in any situation.

Sincerely,

Mel Dawson
Simmons First Investor Services
Raymond James Financial Services, Inc.
Member FINRA/SIPC
Located at Simmons First National Bank
501 Main Street
Pine Bluff, AR 71601