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

August 20, 2008

I think that the SEC is overreaching their jurisdiction.
"Comments Attached"
I think that the NAIC is ample authority to supervise the entire issue of Fixed Indexed Annuities.

The state of Iowa Insurance Commissioner has taken steps to reinforce the FIA marketplace by testing and making all agents be certified to sell them properly and understand them properly.

I think that the SEC is not acting in the best interest of clients.

These products are CLEARLY NOT SECURITIES and never will be, otherwise Life Insurance and all Annuities could become items of supervision with SEC in future and that is not why CONGRESS created the SEC in the first place.

I think that CONGRESS should slap the hands of all SEC leadership for even trying to show their weight in this "off limits" arena of Insurance Product.