Subject: File No. S7-14-08
From: Marc Molina

July 30, 2008

To whom it concerns

I have read insults directed to insurance agents by securities professionals. And since I am an insurance agent, for the purposes of this comment I would like to use the term of "me", "my" or "I" when referring to insurance agents.

They make fun of my lack of understanding of their profession because of the insurance products I offer. Namely Fixed Indexed Annuities or as they call them, Equity Indexed Annuities. One such comment accuses me of deeming suitablity of a senior by using the yardstick of "fogging a mirror". Others speak as if I were child that wants to play ball with the big boys. In general, there is a lot of animosity on their side of the fence.

As a young man I have put my own money with investment professionals. I know that the market can possibly provide my biggest possibility for gains. As I get older though, I've become increasingly aware of the importance of guarantees insurance offers and tax deferral. As the power of attorney for healthcare and finances of a family member, I have gained a new appreciation for the plight seniors have in this unique time in their lives.

Deciding the right path is especially clouded with the name calling and finger pointing that's going on.

As far as considering a fixed indexed annuity a security or under SEC oversight there is simply a misunderstanding of how well the NAIC and state departments work. Their requirements, continuing education, compliance, ethics courses and such are considerable. Surrender charges, current rates, guaranteed minimum surrender values and such are clearly spelled out in the annuity contract. Someone who makes fun of this or dispells this as a low rent version of oversight and enforcement is just not familiar with how well it all works.

I know I know... I saw the Dateline thing too. I heard a lady with a law degree say she couldn't understand the annuity wording... (Ever read a prospectus?). Regardless, there is a little bit of truth to everything. There are agents that do stuff they shouldn't. The industry weeds them out and safegards are put into place to try and keep it from happening again. Insurance deals with these issues and the punishment can be very severe. We are all aware of it. It is no different than offering Insurance oversight of the SEC since there are so many securities complaints. It sounds just as silly because not only are securities not insurance, but insurance is also not securities.

To a senior, an insurance product correctly represents safety and guarantees. Transfer of risk. When sold properly, they provide a significant benefit which allow many to plan when uncertainty can work against them.

I am in no way offering that insurance is the absolute final solution for a senior in retirement. That is up to each to decide for themselves. I am simply clairifing that while it may seem easy for one to make a quick summation of the insurance industry based on a Dateline episode, it should be looked into more carefully. Understand the real reasons why people purchase insurance and why they are so attractive. Toss out the notion that the industry is out to scare and mislead seniors to line our pockets. Look into the always improving but great track record of our oversight already in place. We need to work together for the benefit of the consumers but the bickering puts an exclamation point on why the SEC shouldn't have oversight on insurance. It simply doesn't understand us or our value. And that can never be good for the client.

Thank you,

Marc Molina