Subject: File No. S7-14-08
From: Alan Schuh
Affiliation: Registered Investment Advisor

August 18, 2008

Chairman Cox:

I am writing to express my concerns regarding File No. S7-14-08.

It is imperative to the current generation of retirees as well as the baby boomers that they have a safe haven to place a portion of their life savings which need to sustain them for an increasingly longer retirement.

If 151A becomes a mater of law, it will certainly hinder the publics ability to find a safe place to deposit their retirement assets and have a reasonable chance of staying ahead of inflation which really is a major issue. Other traditional savings vehicles such as CD's, Treasuries etc. have historically not kept up with the cost of living.

Unfortunately, there are sales abuses occurring in every industry including financial. There has been long-term oversight of the securities industry and sales abuses persist. In my 20 years of working with clients, not a single one has lost principle or accumulated interest in an index annuity. That is the reason so many people are attracted to index annuities in the first place.

Placing additional oversight and regulation above and beyond the existing state regulation will not only be expensive and duplicative, but the few sales abuses that exist will continue because some people refuse to do the right thing. The states have done an excellent job of regulating fixed index annuities and will continue to fine tune their processes given an opportunity.

Respectfully submitted,

Alan Schuh, President
Alan Schuh Associates, LLC
Registered Investment Advisor