Subject: File Number S7-14-08

August 27, 2008

Please open and read the attachment to get NAIFA Iowa's response to File # S7-14-08. We believe that these indexed annuities have often been incorrectly called equity indexed annuities.

In my opinion indexed annuities should continue to be treated as insurance products, and the state insurance regulatory structure is the appropriate means for addressing the concerns raised by the SEC. The professional organization I belong to, the National Association of Insurance and Financial Advisors, is committed to working with the NAIC and state insurance commissioners towards the goal of having every state adopt and vigorously enforce the NAIC’s model regulations on annuity suitability and disclosure. I also support NAIFA’s recommendation that a state regulatory body be designated to develop standards for indexed annuity product design so that inappropriate indexed annuity products would be prevented from reaching the marketplace.

Paul R Zietlow

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