Subject: File No. S7-13-08
From: William Morris
Affiliation: Principle - The Morris Group

July 8, 2008


Subject: S7-13-08

Dear SEC,

I have great respect and admiration for the mission of the SEC in the course of its normal and necessary jurisdiction. In the above matter of consideration, I strongly believe the SEC is overstepping its jurisdiction and potentially adding another, unnecesary, layer of regulation to a financial product that is already heavily regulated. For reasons well-established, equity-index annuities are properly classified as "fixed annuities", and as such are very adequately regulated by state insurance departments, above and beyond the rigorous compliance requirements of the individual insurers, and the collective compliance of life insurance companies with NAIC-established guidelines. The life insurance industry, including fixed annuity products, already enjoys the well-earned public reputation of being one of our nation's most monitored and strongly regulated industries. As a licensed industry professional, I fear that the consumer will be negatively impacted by the addition of yet another, unnecesary, dense layer of federal regulation that will further obfiscate this important financial product category from a consumer standpoint. This additional regulation will surely add cost to the delivery of the product to the consumer, which potentially risks having the effect of lessening the financial performance of the product to the consumer because of these additional, unnecesary costs. This is a no-win for the consumer. Mainly because of the risk of negative impact on the consumer, I have to say that I would have a professional obligation to join a class action at law to defend the public against what I believe is an unnecesary and wasteful jurisdictional over-reach by the SEC. Please careful consider what is being proposed, and for the good of the consumer, please realize the jurisdiction problem. This proposed regulatory change will impact the public by obfiscating a crucial financial product category unnecesarily, and cause a chain reaction of cost increases that could easily weaken the performance of those products.