Subject: File No. S7-14-08
From: Bruce E Chadwick

July 31, 2008

As a senior, I think the proposed rule will be the end of the indexed annuity. The guarantees provided by the insurance companies will no longer be available once the product becomes a security. The index annuity fills a void in the investment marketplace between at risk stocks, bonds and other securities and the ultraconsertative such as CDs or savings accounts. This allows one to get a potentially higher return than ultraconservative accounts offer without the high risk involved with securities.

Why hasn't the SEC made an effort to ask the current owners of index annuities if they like them. It would seem to me that the end user would be the person to ask if they thought they needed more protection.

Also, quite frankly, I think the SEC already has enough on its plate. Talk about taking advantage of seniors what about auction securities marketed as money market accounts, the mutual fund companies who paid Spitzer millions in fines due to their unlawful activities. Massachussets is taking action against Merrill Lynch over some questionable things marketed to seniors, I did not see mention of the SEC being involved in that.