Subject: File No. S7-14-08
From: Dave Runyan

July 13, 2008

It should be obvious that "fixed indexed annuities" which are offered with a guaranteed "zero" (no loss)in down market years should be an Insurance Product.

I believe that the biggest problem the SEC has is the absolutely horrendous track record of policing the super-exorbitant fleecing of corporations by executive remuneration schemes. What would be the logic of trusting the SEC under those failed examples?

The SEC is surely being lobbied by all the wall street firms who are appalled by how much money is leaving their coffers. However, perhaps it is finally time wall street lost some of the money it has so poorly managed for so long. In the wall street version of things, the insurance agents who receive a commission up front for the sale of annuities are not entitled to them. However, if the securities rep from wall street received a 1% PER YEAR for TEN years (whether or not the acount made or lost money), how would that not be worse than the Insurance agent receiving a 6 to 8% commission up front (not paid out of the client's money)and receiving a "guaranty" of no down side risk in a market down year?

Frankly, the SEC has proven itself incapable of regulating its industry compared to the regulation of the Insurance industry. There is a REASON why the SEC does not allow the use of the word "Guaranteed" in any prospectus. They are not "qualified" to issue a "Guaranty".

It should also be obvious that "variable annuities" which offer no guaranty are in the pervue of the SEC.

How many Insurance Companies over the years have had to go BK or be merged with another to survive versus the same in the Insurance Industry? Do the research, please. If the SEC did that research and honestly reported the true numbers, they would close the subject and applaud the Insurance Industry for regulating itself as well as it has.

Sincerely,

Dave Runyan