November 17, 2008

Subject: Opposition to the proposed ruling s7-14-08

First, I appreciate your consideration of these thoughts.

I am not even sure why Indexed Annuities are being considered as a security. By definition it is not. It has guarantees. What security on Wall Street has guarantees? What security on Wall Street has legal reserve? What product on Wall Street protects the client from loss of THEIR money? What product on Wall Street guarantees that you can lock in earnings EVERY year and protect the profits? Paper gains are not real until you capture them… I understand why the SEC and FINRA want this product to be regulated by them. It is called GREED. Haven’t we seen enough of the irresponsible behavior and greed of Wall Street?! How is that benefiting us? We need safety and "REAL" security to protect our money.

What we are facing in this country is a "financial tsunami", according to David Walker. He just resigned from the GAO in case you were wondering who he is. I am sure the SEC does not like his messages either but they are truthful and accurate. You can find him on you tube under his name if you want to check it out.

We need a methodology and a system to capture gains EACH year with our earnings and stop Gambling and guessing with our retirement money. Those are not good strategies as a planning tools. There is no way to capture gains when you are involved in the market. You have to move to a cash position EVERY year, which usually drives commissions and then you will need to buy back in because of inflation chewing up your buying power and that usually drives commissions. To me it seems you should be more concerned about the system currently in place and all the fees and commission that take away from returns that how to get more fees commission and charges…

The Indexed Annuity clearly provides what people need. Safety, protection, preservation and control over THEIR own money. We do not need more Government intervention. This product can not be considered a security just because it allows people the (choice) to participate with an Index to capture some earnings. If you take away the Index, all you have is a Fixed Annuity. It goes back to the customer making the choice over THEIR own money.

Thank you again for the opportunity to share these thoughts but please act on behalf of what is best for the people and not what is best for the Government. It is time someone stood up an acted responsible. Other wise who is representing usP and what is the point???

Stephan M. Lemmond
Lemmond Financial Group