November 17, 2008

Subject: File# S7-14-08

My name is Joe Holcombe. I have been in the insurance field since June 1984. I was the president of the Greenville SC Association of Life Underwriters in the year 1995-96. I have always believed in the value of Guarantees that my clients will not lose money with the products I have used to help them with their retirement planning. For the last few years I have used Fixed Index Annuities because these products have the ability for their money to get a good return with no risk of loss. To give two examples: one of my clients is an 83 year old lady who came to me in 2007 and in her own words she was "terrified" because she had $117,000 in a mutual fund investment and that was all the money she had. We moved her money into a Fixed Index Annuity. If she had left her money in that fund, in the last 15 months she would have LOST approximately $35,000 of her money. But in the Fixed Index Annuity, she HAS NOT LOST a penny!! I have another client who is disabled from a stroke and we moved his $110,000 401k into one of these Annuity products two years ago. Had he left his money in the investment he would have lost about 30% of his money. This man called me today because of the news about the stock market. I was very glad to tell him that he had not lost any money in his Annuity account!! With these facts in mind, I am fully convinced that FIXED INDEX ANNUITIES ARE NOT SECURITIES and therefore should not be regulated as such. Also, there is no "unfair or abusive sales practices" being done in protecting someones' hard earned money! Thank you for your serious consideration of these matters.