Subject: File No. S7-14-08
From: George B Lynas
Affiliation: CLU, CHFS, CPA, Member of Nafia Finra

August 22, 2008

Unlike Nafia Finra, I totally support this rule and the SECs attempt to classify indexed annuities as investment products.

These products are missold and misrepresented to the public by many insurance agents as investment products. The term frequently used is "stock market gains without risk" and "share in upside of market without downside". The product is to confusing for the public and cannot be adequately regulated by an insurance commissioner that does not regulate investment products. It is more like a variable product which is already classified as an investment product.

The misrepresentation of this product has gotten worse as the better broker dealers have forbid their represenatives to sell this product. The result is that the product is being sold by less qualfied reps, working for broker dealers that do not supervise their agents. It is also being sold by insurance agents that do not have a brokerage license.

I have personally seen this product misrepresented and uninformed buyers sold a product that they do not understand with huge fees and penalties that they are not aware of.

The SEC should immediately become involved with the sale of Indexed Annuities and I support your attempt to regulate this product fully.

Thanks,

G. Barry Lynas
469-633-1676