Subject: File No. S7-14-08
From: Raymond C Phillips
Affiliation: V.P. Insurance Sales

July 14, 2008

Indexed annuities need to stay with the insurance departments at state level. The burdensome oversite and regulation required of the securities industry is too costly and unnecessary. The insurance industry can police its own. I am responsible for training insurance agents at my company. Ethics, integrity and suitability are not merely terms we use --they are pactices we employ. The securities industry does not need to interfere with the insrance industry.

Unlike securities, index annuities have no loss of risk to principal. Do not need to be regulated as securities.

The dateline article on television was skewed, biased and poorly reported. The SEC should base decisions on facts

Ray Phillips