Subject: File No. S7-14-08
From: Michael C. Robinson
Affiliation: Ins. agency owner - agent - registered rep

October 21, 2008

I believe the insurance industry has developed a safe, sensible product for people in or near their retirement years. The fixed indexed annuity is a conservative "safe money" alternative to mutl. funds, variable annuities, and CDs.
In the past couple of weeks I've received calls from clients who thanked me for suggesting a fixed indexed annuity to them. They haven'tlost a dime - their friends in the market - that's a different story.
The industry is diligent about suitability and replacement issues. I see no need for the SEC to regulate this product when there is so much that desperately needs fixed under it's already crowded umbrella.
The current market debacle suggests that there is plenty to fix already. Why borrow trouble ?

Sincerely, M.C. Robinson