Subject: File No. S7-14-08
From: Ethel M Muhammad
Affiliation: Insurance

September 4, 2008

Please extend the comment period.

Indexed Annuities are fixed annuities that, like traditional declared rate fixed annuities, guarantee a minimum interest crediting rate and provide the opportunity to earn interest credits in excess of that guarantee. The indexed product offers the consumer a strong minimum guarantee backed by the insurance company along with the opportunity to earn excess interest that is hopefully higher than traditional principal-protection products. State insurance regulations cover, among other things, suitability of insurance agent recommendations regarding annuities, annuity disclosure and advertising, agent licensing and training, unfair trade practices including misrepresentation of product terms and conditions, and enforcement actions and penalties for noncompliance with sales practices requirements. Securities regulation will add little benefit to consumer protection. The guarantees provided by an indexed annuity offer consumers significant protection against investment risk.