November 13, 2008

Subject: File No. S7-14-08

I am encouraging the panel not to enact this change for Indexed-Annuities to be classified as a security. Throughout the last century and into the 21st, Life Insurance agents and brokers have be helping people prepare for their economic future and welfare. Why now are those dedicated advisors to be excluded from using a tool that has proven to be beneficial to the public? It is obvious that FINRA and other self-regulating organizations have not protected the public from the current securities and economic disaster. Had every investor had had their money invested in an Indexed Annuity, they would not now be suffering from a 50% loss in their equity.

The Indexed Annuity owner is not participating in the securities market with a purchase of this type of contract. It has built-in guarantees to mitigate down markets. Contrast that to a Variable Annuity that cannot, by it nature, guarantee downside protection. Let sellers of market participating products continue to be subject to securities regulation and supervision by the SRO and let insurance agents and brokers be subject to each state’s department of insurance.

Other professional associations are promoting passage to enrich their own position as advisors and the resource for this type of product.

Charles G. Jimison, CFP®, CIC, CWCA
Partee Insurance Associates, Inc