Subject: File No. S7-14-08
From: Dennis E McCarty
Affiliation: Past President NAIFA-GI

August 4, 2008

To whom it may concern,

Let it be known to the powers that be that I am opposed to File S7-14-08, with regards to Indexed Annuities and other similar Life Insurance products coming under the jurisdiction of the SEC.

I have been in the Insurance Industry for 26+ years and the Indexed Annuity product has given me another opportunity to assist my clients with putting money away for their future financial needs. This is something not many are doing in this day and age. I can feel comfortable making this recommendation to the client because I know that I am not risking their life savings to a possible loss when the markets are struggling as they are today.

As an insurance person I do not advise my clients on the direction of their Security Investments because I am not a Securities Licensed individual, nor do I ever plan to be I know my comfort level when it comes to advising persons on where to put their hard earned money. I am by nature a conservative person.

The Indexed Annuity product is a "Conservative" product for those who fully understand it's usage in the future planning process of their clients. Those who sell it differently then this are misrepresenting the product, much like those who promote large returns on Securities and fail to speak of the tremendous potential for loss on the down-side.

Abuses by unscrupulous people can be found in all areas of our industry. With regulations of the Indexed Annuity product coming under the watchful eye of the NAIC and the respective State Departments of Insurance I see no need to have the SEC step in on a regulatory position with a product that does not deal with either the agent or individual consumer picking a stock, bond or and equity fund. The SEC already has enough to monitor within the ranks of the Banking/ Secuities areas. Why would they "want" to take on more if the need to do so isn't there?

Thank you.

Dennis E. McCarty FIC, LUTCF
Past-President, NAIFA-Grand Island
1-308-384-8700
Member of NAIFA, NAHU, AALTCI