Subject: File No. S7-14-08
From: Ronald W Johnson

August 11, 2008

To Whom It May Concern,
It appears that the SEC wants to control the fixed interest rate market as well as the win or lose securities market. People do not buy Fixed Indexed Annuity for their risk of loss. People purchase FIA's because there is no risk to their principal.
It is extremely important that those who are wanting to have the SEC in control understand that the Fixed Index Annuity is not impacted by market fluctuation negatively. The annuity purchaser may not have a return do to poor market performance, but will not suffer any loss to their principal inside of the FIA.
Some attention shouild be paid to the ruling in the Malone V. Addison Ins. Marketing, an FIA is Not A Security.
I think that it also is important to understand that an individual can contact their State Insurance Dept. and get a resolution regarding any problem they may have with the Agent or the Annuity they have purchased without going thru the legal system and using an attorney as is so often needed wih securities.
One last comment in closing. Why is the SEC so focused on FIA and not really interested in pursuing indexed C.D.'s or Indexed Universal Life. The old saying would be that if one indexed product is a security then they all must be securities. Lets move forward with the Insurance industry handling the Fixed Index Products and the SEC handing those that truly have a risk for loss to ones principal.