November 13, 2008

Subject: Equity Indexed Annuities s7-14-08

As past CEO of NAIFA, I object to the SEC’s potential regulation of Equity Indexed Annuities. The index is a measure of the rate of return and is not the measure for losses that might be sustained – since risk of loss is not a viable problem. This is much more a guaranteed product than a security and should be regulated as such. Please do not read that I am opposed to regulation. Far from that I am much in favor of it. I just believe that either the states or an optional federal charter would create a regulator more familiar with insurance issues.

Thank you for your allowing comment.

Sincerely,

Arthur D. Kraus, CLU, ChFC
Capital Intelligence Associates, Inc.