November 13, 2008

Subject: File No. S7-14-08

I have spent over 23 years providing advice to consumers, some of those years I acted as a securities broker and insurance agent. I have been to countless insurance seminars so I'm very familiar with how insurance agents think and behave when it comes to marketing the products they choose.

Much damage is done to consumers and our nation's financial system when "innovators" are able to call a duck something other than a duck. We've also seen what happens when there is insufficient clarity of the inner workings of complex securities.

CDS's are a prime example- they are insurance and while they may not need exactly the same kind of oversight as other insurance, it is now obvious that they still need oversight. Another example is the CDO market where complexity became disaster, once again due to failure of oversight as it was believed the industry would self police.

Equity Index annuities are securities- they have returns that are based on market conditions and they are sold on the basis of participating in markets- they need securities oversight.

They are also enormously complex making it nearly impossible, even by seasoned agents, to judge whether a particular contract provides a good or bad deal to the consumer. They need to be called securities and compared to other securities in a way that will allow consumers and agents to understand their potential risks and rewards.

Finally, there are many excellent people working in the state insurance departments, however they generally do not have the resources or the skills to assess securities, especially given the disparity in resources from one state to another.

Bill Ramsay, CFP
Financial Symmetry, Inc.