Subject: File No. S7-14-08
From: Robert L Franca

September 8, 2008

By definition of the product - indexed annuities cannot be considered an investment under the SEC. The reason for SEC protection is to protect the public from losing money due to advisor recommendations. The main protection feature of an indexed annuity is the fact that consumers cannot lose money.

There are problems with unsuitable recommendations in every insurance product, not just indexed annuities. The SEC is also overtaxed in just trying to keep up with the products that currently remain under their rule.

In my opinion this is just a ploy by Wall Street (FINRA) and the fact that they want a piece of the financial pie being generated outside of their jurisdiction.