Subject: File No. S7-14-08
From: Norris W Tingle, Jr

August 11, 2008

I strongly believe indexed annuities to be insurance products, not securities. Indexed annuities protect the principal deposits, while many times yielding a greater gain than fixed return values. While there have been some problems which have been addressed by State regulators as regards marketing practices, the vast majority of insurance agents and insurance brokers are competent and compliant in the best interests of their clients. In my view, the SEC is hardly the theater for regulating these products. My clientele depends on me for such vehicles, and have never used a FINRA broker. The opportunities for gain in the market are commensurate with the liabilities of loss, and my clients do not wish such exposure. Their risk tolerance is totally nil. Further, I do not believe that the federal government is the best venue for consumer protection, based on its current track record.

Thank you for considering my opinion.