Subject: File Number S7-14-08

August 27, 2008

I am licensed to sell the equity indexed annuities. My clients like these products because they have a minimum guaranteed interest income amount, deferral of income tax, and the possibility of increased gains if the indexes increase.

I make clear to them, whether they purchase a traditional fixed annuity or one of the newer equity indexed annuities, that there is a surrender period and related charges. I also make clear that they must have other assets from which to draw funds during the surrender period.

I believe it is inappropriate for the SEC to regulate these products since they are not variable products. I stopped selling variable products years ago because I did not want to sell investments which could lose money. I am dedicated to selling only fixed investments. If an investor wants a variable product, they must deal with another representative.

I strongly encourage the SEC to withdraw its proposed Rule 151A.

The difficulties in the marketplace with sales reps who mis-represent these products or sell them in an unsuitable situation are better handled by the State Regulators.

The above problems are not criteria to judge whether the SEC should have jurisdiction over the product.

Unscrupulous sales reps should be prosecuted for their methods but to try to solve that problem by including the equity indexed annuity products under the SEC is the wrong approach.

Our professional organizations are fully behind the efforts to prosecute unscrupulous sales reps. Such sales mis-representation can occur throughout the industry in ALL products. That doesn't mean ALL products should fall under the jurisdiction of the SEC.

These products and their attributes should qualify them to continue to be treated as insurance products subject to the State regulation.

I appreciate your attention to my views and request.

Randall R. Norton
CPA, CFP, CLU, ChFC, CSA