November 4, 2008
Please reference S7-14-08 for the folowing comments.
It is my opinion that Indexed Annuity Contracts and /or Optional Annuity Contracts remain under the control and supervision at the State Commission level.
Indexed Annuity contract growth is a product of an Equity Index but remains a fixed annuity contract. Contract owners may have choice in the index used as well as the portion or percentage of the contract deposit that is placed into the Index related amount but does not have access or any entitlement to, day to day activities of investment.
Contractually it can not have a loss of the deposited amount and does not carry the risk associated with an accessible equity instrument.
Changing the status and the methods of access that individuals have to these products would prove to be detrimental to the savings product options and opportunities that are supplied to them by their local Life and Health Agent(s) who have chosen, or may nor have acess to a Broker Dealer relationship.
It is important that Indexed Annuities remain as they are, with State controll and ease of access.
Thank you for your consideration of my opinion.
James Shaffer