Subject: File No. S7-14-08
From: John M. Simon
Affiliation: Master Certified Retirement Specialist, M.Div.

November 17, 2008

Dears Sirs:
This letter is to comment on the proposed Indexed Annuity rule in which the SEC would govern these products as Securities.

This morning I met with a retired couple whose IRA savings of over $170,000. was reduced by a Morgan Stanley representative to zero through a series of inappropriate trades.

Last week I met with a couple in their 80s whose annuity was rolled over at the urging of the Bank of America Securites salesperson and is now worth less than half of what it was originally worth.

I have come upon many similar situations, dating back over the 35 years I have been in the Annuity business.

Thus I have this comment: If the SEC protects the prospective buyers of Index Annuities the way it protects the people who it currently "protects", the American public will be much the worse for it.

Index Annuities are not securities, and are well governed as it is by the state insurance commissioners.

Respectfully Submitted,

John M. Simon