Subject: File No. S7-14-08
From: Michael J. Grooms
Affiliation: Insurance agent- broker

November 20, 2008

MY BACKGROUND
I've been in the insurance business since september 1976.
I am a college graduate with a degree in marketing.
I have always continue my education to improve my skills in
assisting my clients in every way that I can, without the goverment requiring it.
I have always given back to my profession by teaching LUTC
(insurance classes), cources to younger agents.
I have held basic securities licenses,(which I retired 3
years ago), because of all the time I was spenting in compliance, I realized that I was not utilizing my time to revisit and reviewing my clients needs.

Now for my comment, reguarding the SEC's needing to take charge of over-seeing Index annuties Look at the great job the SEC has done in overseeing regulating the big boys on wall Street / big companies handling employees retirements ,etc the list goes on.

The percentage of complaints to insurance annuity
companies is and always has been very insignificant compared to total contracts written. Most often the complaints are unwarranted. Valid claims have been handled well by the insurance commissioners of each state. ( this is part of their job description and has always has been). The public would be better served to place reasonable restraints on attorneys. State insurance commissioners have set new requirements on agents continuing education and ethics, which goes straight to the source of most of annuity complaints. I am very pleased with the conduct and performance of our current governing body and trust them not only as an agent but as a consumer.

I truly believe that the SEC should STOP,trying
to expaind its authority in areas already being over seen
by a goverment agency. This is like a family squabble of
two brothers fighting to be in charge. It's meerly a
struggle of power to become more incharge. The SEC has a poor track record in over-seeing its current obligations.
Look a the current enviroment that the SEC has been handling. Turn on your Tv newscast. All the current problems in our financial system were being watched by the SEC.

The same thing has been occuring in corporate
America. Banks gobblingup smaller banks, insurance companies buying out other companies, mortgage companies
aquiring other mortgage companies. All in the name of
consolidation profits. The larger the company the
less personel service given. The ONE WHO ALWAYS LOSES
IS THE CONSUMER, in consolidation, no matter how they
sell it to the public. Goverment is no different, if the
SEC gets control over index annuties it will be the CONSUMER who will lose. They will have less access to a
larger governing system and poorer personel service for the consumer.

I have seen this over over again in my 32 years
in the insurance business, even in my own industry.
As an example call almost any insurance company... a computor answers the phone. You must guess which prompt
will best get you the answer to a simple question. No one
signs a letter anymore its always a department or some times not even that, therefore no one takes responsibility
even in the letters they send out. We get more servicable
touch in mass mail outs with a computor inserting your name
instead of (resident).

If the SEC is given the responsibiliy of index
annuities the consumer/public will lose again Because it
will lose me A 32 year veteran agent who cares about the
needed of his customers and in finding the best solution to their personel needs, one on one.

I will No Longer spend my valuable time
complying to the SEC, when I could be spending time in front of person who needs my guidence in solving his
problems.

Sincerely

Michael J. Grooms