Subject: File No. S7-14-08
From: Dan Smith

July 23, 2008

This is a case of gross and forced 'parenting' where there never was a need to do so.

The fact that indexed annuities are in fact fixed annuities with a mirror of the stock market and not the exact image is proof enough.

A mirror image only mimics the actions of its original. It is NOT the same. Where the original DOES have the downside risk, the mirror image does not.

This is simply a power grab by never do well bureaucrats without regard to the public good but for the agrandizement of their own position.