Subject: File No. S7-14-08
From: Brenda L Kobrin
Affiliation: Insurance

July 24, 2008

I strongly oppose the proposed legislation to classify Fixed Indexed Annuities (FIA) as securities, for many reasons.

1. These are truly fixed products in that purchasers' principal is completely safe from decreases in value. People buy these products primarily for SAFETY, not for growth. They hope for growth and like the idea of earning more if the stock market does well, but they are not purchasing a FIA to be in the market. They are there for safety, primarily, knowing that market flucuation cannot hurt them.
2. The benefits and rewards of FIA products are very similar to traditional fixed products. Although a contract may earn more or less in various years, overall the earnings are similar to traditional fixed products.
3. I believe that consumers are well protected by the suitability regulations that are already in place and that they will not be better protected under SEC regulation.
4. I believe that SEC regulation will reduce competition by squeezing out many excellent professional financial advisors and retirement planners that have focused on fixed products for the safety and wellfare of their clients.
5. I believe that SEC regulation will increase the cost of administering these products, which will necessarily decrease the value of them for consumers.
6. I am certain that this proposal originates from greed and not from a desire to protect or to offer more value to consumers. It is clear that the popularity of FIAs is what is driving this proposal, not any real grounds for declaring them securities. Why are indexed CD's and/or indexed UL's not included in this proposal?