Subject: File No. S7-14-08
From: Robert Myer

December 7, 2008

It is foolish to allow insurance agents to sell equity indexed products without being regulated by a securities regulatory body. A sales presentation cannot be made without reference to securities and security indexes. The idea that the public can get proper disclosure on an equity indexed annuity is unrealalistic. Insurance Companies are currently designing life insurance products that are not annuities that they believe their agents will be able to substitute in the event that equity indexed annuiyies become regulated.The SEC would be well advised to include all insurance products that have equity indexed features in their final regulations.