Subject: File No. S7-14-08
From: Jefferey Waters

August 20, 2008

The SEC has a persistent belief in a mistaken idea.
Please let us concentrate on a proposal that ignores exisiting case law surrounding the Securities ACT of 1933, which exempts from registration products sold by insurance companies.
The proposed rule makes it clear that the SEC is ignoring the unique aspects of index annuities that make them insurance products. ...And it appears the SEC does not understand that there are state laws in place to protect consumers from unsuitable sales,
prohibit fraudulent and misleading sales practices,
require full disclosure and free return of unsuitable policies, and
provide non-forfeiture protection and minimum interest guarantees. Key word is guarantees by the insurance company. This a not subject to market risk and not subject to the jurisdiction of the SEC.