Subject: File No. S7-14-08
From: Michael Baumann
Affiliation: CEO, Honor Financial Group

July 31, 2008

The recent actions by both FINRA and the SEC concerning annuities and other insurance products that offer returns linked to various market indexes with minimum guarantee features appears to be either misguided and/or self-serving.

These various products offer secure guarantees. Many of our clients, including senior citizens, have been very pleased with the performance and safety of these vehicles. There is no more downside risk than if one had invested in a bank CD. The Rule of 100 would indicate that many of these clients are well suited to very safe investments, including CDs and annuities.

For younger clients, a variable annuity, mutual funds, or other security may be suitable due to the client's longer time frame. They may have time to recover from market downturns. This is not the case for many seniors.

Labeling insurance products that are already highly regulated by state insurance departments as securities will reduce the availability of these products for the people who truly need them.

I have been licensed for both securities and insurance for many years, so a decision to lable these insurance products as securities will not diminish our ability to offer them. It very well may limit the number of products for us to choose from.

Hopefully the SEC will not cave in to the desires of FINRA to try to regulate every product in exisitence. Other insurance products are no doubt in their sights as well. It's hard to imagine any other true reason for their actions other than for profit and fees. Always, follow the money.

Sincerely,
Michael Baumann