Subject: File No. S7-14-08
From: Jerome Kanter, JD

July 30, 2008

Fixed indexed annuities are not securities. While the interest crediting mechanisim is linked to a security based index or indices, the product is a fixed annuity, and as such is an insurance product. While there may be issues regarding the complexity of the products' interest crediting mechanism(s), as well as sales practices, suitibility and consumer education, the SEC has no business trying to insinuate itself into a regulatory environment best handled by the state insurance departments.