Subject: File No. S7-14-08
From: Kirby V Nielsen
Affiliation: Retired Insurance Agent

November 10, 2008

November 10, 2008

Sirs:

It is my opinion that indexed annuities are insurance products and not securities. Hence their regulation should remain under appropriate State regulations.

The basic premise of the product in the accumulation portion of the policy is a guarantee of at least a return of premium. In many cases, there is stated guaranteed mimium return of principal plus interest. It is the guarantee which differentiates the insurance product from investment products.

State insurance regulations requiring reserves, state guarantee funds, and meeting industy standards for investment quality makes the product as secure as any financial product in the country at this point.

No additional regulation is needed. I oppose treating any annuities as investment product. Consumers are safer with State regulation than they are with Federal regulations, which have been shown to be severly inadequate.

Kirby V. Nielsen
Delaware, Ohio