Subject: File No. S7-14-08
From: Alan Hallerman

November 13, 2008

To Whom It May Concern:

It is my personal opinion that the SEC has no place in the governance of Indexed Annuities. Indexed Annuities are clearly insurance instruments and that alone makes them out of the scope of the SEC. However, to take it a bit further; the fact that the reason this is being considered is due to the actions of a few rogue agents taking advantage of unsuspecting buyers is no real reason at all. The fact is that there are clearly more people taken advantage of (and hurt much more) by those securities licensed agents than the entire insurance market combined!

If an agent sells an indexed annuity to someone on false pretense, at the very least the buyers money is 100% secure because it is INSURANCE! If a rogue securities agent takes advantage of an unsuspecting person and sells them a security product, their money could be GONE! Legal action may or may not remedy this occurrence; however, in the former instance the buyers money is there and under MOST indexed annuities the MOST money that could be "at risk" for the buyer is 10% - 12% as that is the normal surrender charge in the first year of purchase. By going after the agent, the agents E&O will clearly cover this loss!

Indexed Annuities are INSURANCE products and have no place being overseen by the SEC!

Respectfully,
Alan Hallerman
Licensed (And HONEST) Insurance Agent