Subject: File No. S7-14-08
From: Sanford L Schenberg, CPA , Attorney, Insurance Agent
Affiliation: Missouri and fIllinois Bar

November 17, 2008

I oppose strongly any changes in how FIAs are regulated.
The Federal Government has done a poor job handling
securities, banks, etc.
State governments have done a far superior job than
the Federal Government. They have handled insurance
companies well, and are doing a good, on-going, and
extensive job of handling FIAs(fixed index annuities).

Federal intervention in the FIA market will just add
a lot of rules, paperwork, and costs, reducing returns
to seniors, and driving insurance-licensed only(no
securities license) agents out of the market.

In the recent downturn, the Federal government has
been exposed as doing a remarkedly poor job as a
regulator. AND THE STATE GOVERNMENTS HAVE BEEN SHOW
TO HAVE DONE A MUCH BETTER JOB. NO OWNER OF AN FIA
LOST A PENNY OF PRINCIPAL. INSURANCE ONLY COMPANIES
HAVE COME OUT UNSCATHED.

PLEASE, DO NOT RUIN SOMETHING THAT WORKS WELL. YOU
HAVE RUINED ENOUGH ALREADY.