Subject: File No. S7-14-08
From: Rosslyn Carrier

July 28, 2008

I oppose the adoption of proposed rule 151a by the SEC, because it is an unnecessary ruling that amounts to GREED and commission grabbing that will greatly disadvantage the general public.
Fixed Indexed Annuities ARE INSURANCE PRODUCTS THEY ARE NOT SECURITIES and if held to the end of term theres NO RISK OF LOSS, the insurance company accepts all the RISK.
There is no need for a Prospectus as required by variable annuities, where the insurance company passes all the RISK to the insured
The fact is consumers purchase Fixed Index Annuity because they are FIXED. They don't want the risk other products place them in. This is the same reason they put money into Savings Accounts and CD's, and not a security.
There is no need for a monthly statement like securities because these annuities are a safe investment with no risk – there is no need to monitor these policies on a monthly basis. Their term is annual, interest and growth is credited on an annual basis. Fixed Indexed Annuities have no brokerage commission to the annuitant/owner, no annual fees, and no cost for changing indexed interest rate strategies.
There are good insurance agents and there are bad. The same thing can be said about a stockbroker, there are good ones and bad ones. Suitability issues have been addressed, and suitability regulations and sales practices already meet and surpass that of Federal Regulations through State Department of Insurance offices and complaint resolutions by DOI's, then by any SEC law.
The Fixed Indexed Annuity looks like a guaranteed insurance product, pays off like an insurance product, and offers the safety of an insurance product------IT MUST BE AN INSURANCE PRODUCT