Subject: File No. S7-14-08
From: Marvin E. Lyon

November 17, 2008

Comments attached:
Gee SEC,
What gives you the right in a "free-society to dictate-terms" to the insurance-industry? Does the insurance-industry dictate terms to the SEC? No, they don't I wonder if it's because the broker's brokerage houses are losing money (fee-based accounts) as people are seeking safer more guaranteed ventures? Or maybe it is because they (SEC/brokerage houses) want to manage/control all products charge a fee? In a recent front-page headline in the Santa Barbara newspaper " DOW, The Worst Week in 94 years" In a recent episode of 60 Minutes, Morly Safer interviewed Ted Turner asked him "Ted, why didn't you stop your losses instead of letting it go down 7 Billion dollars?" This would not have happened in a repective Fixed-Index Annuity. On the contrary since inception, back in 1995, there has been no losses in EIA's, FILA's or FIA's. This is one ( of 58 companies) incredible product Nor, has any of my clients lost any hard-earned dollars in there respective IRA's, 401k's or there Trust accounts These products are already approved regulated through every state insurance department in the USA Enough said, stop this ridiculus bill or sanction of an insurance product.

In God WE Trust,

Marvin