Subject: File No. S7-14-08
From: Steve J Sadowy, CLU

July 30, 2008

I am appalled that the SEC has come out in favor of the securitization of indexed products. What about the banks (Indy Mac?). Why punish and overregulate 95% of the agents selling indexed annuities---when the problem has been created by 5% or less of the agents in the field. Give additional scrutiny to the few agents that have been sanctioned,or fined or had some administrative action taken against them. Sanction those agents who have had numerous complaints filed against them at the State level-----and let the State handle their ability to continue/or not, selling indexed annuities. Don't punish the vast majority because of the nefarious activities of a small minority. Limit surrender periods to ten years or less---and you will have solved half the problem. That's right---make your 151A proposal apply to anyone that sells indexed annuities with a 10+ year surrender period. Give companies a 90 Day "cooling off" period....to make these necessary changes to their portfolios---and if they make all their products 10 years or less (on the surrender side)---then you can table your 151A proposal "until further notice".
I believe you will see a dramatic decline in consumer complaints and heightened compliance. Anyone who sells lenghty surrender charge products, does it for one reason- commissions. You know it and I know it...Put 151A on hold, and let the quality agents continue to serve the public with principle protected products.