Subject: File No. S7-14-08
From: Ernestine S Cohn
Affiliation: NAIFA

November 18, 2008

I have been in the life and annuities business since 1980. I am also a 78 years old senior citizen. I was personally licensed for series 6 and 63 until 1996. Because I deal primarily with seniors, I did not believe the variable products were suitable for them. I do, however believe that the indexed products are safe. The idea of regulating indexed annuities as a security is ludicrous. It is a respectable fixed product. There is no downside to this product. The client can never lose their principle as they can with investments in the stock market or with a true variable product that contains investment choices. All the risk is assumed by the insurance company and none by the buyer. In addition, the department of insurance and the insurance companies have very strict education requirements for annuities to protect the public. It is not necessary to add another layer to this product. If there are people in the business not following the rules then they should lose their licenses. Adding more bureaucracy will not solve the problem.
Thank you for listening to my opinions.