Subject: File No. S7-14-08
From: Rex D Hill

July 11, 2008

This proposal is unnecessary. Unlike other investment properties regulated by the SEC the Indexed Annuity does not have principal risk which would be tied to an Index. Taking this position would be the same as saying an portfolio based Index has an element of loss to the consumer. We all know this is nonsense.

The insurance industry is doing a good job of regulating the sale of Indexed Annuities and it is not necessary for the SEC to step in. Of course you will not be asking for more taxpayers dollars to help you regulate the sale of Indexed products, would you

You will be placing thousands of jobs for life and annuity licensed insurance professionals at risk. In addition the production of Indexed Annuities will substantially decrease and state revenues for premium taxes will also reduce. Registered Reps can sell these products, but they choose not to do so in any measurable quantity. What you are proposing will substantially reduce production of this product.

Of the hundreds of thousand EIA sold in this country the complaints are percentage wise substantially under the complaints you receive on Registered Reps selling equity based annuity or other products.

This legislation is not necessary and I would hope you do not pursue this further.