Subject: File No. S7-14-08
From: Kenny Kittrell
Affiliation: C.S.A.

August 5, 2008

I have read your proposal on 151A for making indexed annuities regulated as a security. First I am glad you are concerned about the consumer as I am sure some products have not been fully explained to the consumer. I have been in the insurance business for 18 years now and I do not agree that indexed annuities are a security because the consumer has NO risk when the market goes down like a security. I have NEVER had a client lose one dime in a indexed annuity. You have not mentioned in your proposal that the insurance company has to buy options to protect any loss due to a negative market, that is the guarantee a consumer has of no future loss due to a negative market.
A indexed annuity is not always a good investment for everyone, that is where a agent needs to make sure it is suiteable for that consumer. Everyone's needs are different, but a indexed annuity can be a excellent planning tool for many people. In my opinion there have been many more obuses to senior citizens when it comes to variable annuities. The broker fails to tell them about the risks and all the high charges of a variable annuity. I have never run across anyone that owned a variable annuity that understood how they worked. None of them knew they were paying for life insurance that would probably never pay anthing back to the consumer. If you are concerned about the consumer then you need be looking at the variable annuity, not the indexed annuity. I think the state insurance departments are doing a good job on regulating the indexed annuities and do not see the need of your regulation.

Sincerely, Kenny Kittrell