Subject: File No. S7-14-08
From: John G Wirth
Affiliation: Financial Advisor (RIA)

August 7, 2008

Gentlemen,

I had been in the securities business from 1968 until 2007. I produced, managed and observed the regulations of the SEC, NASD and NYSE as well as those of the Insurance Industry (state by state) for nearly 40 years. I worked for Merrill Lynch, Dean Witter (later Morgan Stanley) and Legg Mason). I think I am qualified to comment on the proposed securitizing of Indexed Fixed Annuities. I have literally been on both sides of this question.

If the prime objective of the SEC is to curtail excesses in the sale of this product I beieve the self regulation of the Insurance Industry has already put disclosure documents, ethical instruction and other measures in place that obviate the need for SEC involvement.

If the objective is to remove non-registered insurance agents access to this product in favor of broker-dealer representatives, that would a blantant restraint of trade that I would think will end in litigation by the agents as a class.

Broker dealers already have access to the product and I must say that those who even now about it (who I know) are so ignorant of the nuances and operation of this type of annuity that it is frightening. I would advise the SEC to look to its own house before encroaching upon products that are not and bear no relation to classical securities.

Thank You, John G. Wirth.