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

July 18, 2008

The only reason Securities Brokerage houses (SBHs) want access to this product is because they are losing millions of dollars of revenue as consumers seek the safety of the insurance products.
This is no secret as industry periodicals have been showing the movement away from individual stocks and the stock market since the early 2000s and earlier.
To mitigate their losses, first they (SBHs) tried to denegrate the product. When that didn't keep consumers from moving their funds they next tried to impune the integrity of insurance agents (which still exists to today) accusing them of incorrectly selling the annuity products. Still that didn't staunch the flow of funds out of the market so their next tactic is to claim the product is a securities product and should be regulated by the SEC.

With no market risk and the guarantees associated with annuity products it doesn't take a rocket scientist to see this is no securities product. If the Securities Brokerage houses (SBHs) want access to the product and want to do the right thing for their clients they can get their insurance licenses and sell indexed annuities. But they won't do that because they consider insurance products beneath them. Instead they now try to pull the product under their purview.

The consumer is seeking the security and safety of indexed annuities. At this point in time and with the economic uncertainties at play, they want safety. If the SBHs were interested in their client's best interest they'd be getting their insurance license and selling the product instead of acting like spoiled children who won't play in anyone elses sandbox but their own.