Subject: File No. S7-14-08
From: Cindy C Smits

November 17, 2008

Fixed Index Annuities ARE NOT a securities product. They have a GUARANTEE and are a fixed product. Part of the mess this country is in is because of Wall Street and Credit Default Swaps. Why didn't you have better control on them. You allowed this to happen under your nose with no regulation.

Wall Street and the brokerage houses were the ones that were crying the blues that FIA's should be regulated under the SEC because so much money was going into FIA's because......they have fixed guarantees. Wall Street and
the brokerage houses wanted a piece of this business since a lot of people do not trust Wall Street and brokerage houses (looks like they had a right to not trust them).

My clients that have purchased FIA's are VERY happy with this product. I think it would be best to leave these products as fixed products regulated by our insurance license and insurance companies and instead spend that time finding out how these Credit Default Swaps were allowed and follow the money.

I can assure you, the money that flowed through that channel and has damaged our country should have been regulated by you.

FIA's are not broken, so there is no reason to fixed them but...........these other areas definitely need fixing and......the American public has a right to know how this happened right underneath your nose.

Again........Wall Street always being greedy trying to get more money instead of doing the right thing for the client. Wall Street doesn't care about the client......just themselves. We care about our clients and what is best for our clients.

It would be a travesty to put FIA's under your scrutiny just because Wall Street was crying the blues trying to get more money so using the guise (sp?) that these were being sold at a security product. In my opinion......the bigger problem are these Credit Default Swaps and how that was allowed to happen unregulated right underneath your nose.

I'll bet if you took a survey of all clients with FIA's and asked if they were happy with their FIA's.......I'll bet it would be a unanimous YES. I wonder if the Wall Street guys would get the same response.........

Thank you for your consideration.