Subject: File No. S7-14-08
From: Anthony Pellegrino

November 4, 2008

I am sure you have received many long detailed explanations on why it is not a good idea to make index annuities securities. I would like to keep it very simple.

#1 Is the SEC really reliable? Let’s look at what has happened on WALL STREET. That is the main reason our Economy is in the position it is in. The SEC was “monitoring” Wall Street and look where it got us. Senator John McCain is calling for the immediate removal of the SEC Chairman Cox. Cox is the one who is spearheading this and his credibility is SVERELY TARNISHED. If the SEC failed miserably to monitor Wall Street, why should they be trusted to monitor another industry?

It makes absolutely no sense.

#2 During this tough stock market time index annuities are offering guaranteed principal products that HAVE NOT LOST A DOLLAR! Which of the two industries have provided more safety?

#3 YOU CANNOT LOSE ANY MONEY IN AN INDEX ANNUITY FROM STOCK MARKET LOSSES. Index annuities are NOT invested in the stock market, therefore why would it be considered a security?

If you would like to work with the Insurance Industry and ask them to enforce more training for licensed agents etc… that is a good idea. However, to be managed by a commission that has not been successful at regulating its own industry, not smart.

I believe the SEC has enough work cut out for itself trying to repair its own mistakes. There is no reason to get involved with the Insurance Industry in which clients principal is 100% protected.

End of story.

Anthony Pellegrino