Subject: File No. S7-14-08
From: Richard D Garrett, LUTCF, FIC
Affiliation: National Association of Insurance and Financial Advisors

December 16, 2008

-As a major producer of fixed indexed annuities for several years, I am ardently proposed to the classification of these products as securities. We are currently extremely well-regulated through our individual state insurance departments and through the manditory training from our companies. Not a single indexed annuity client has suffered loss during this current financial recession, whereas almost all those invested in "securities" under your regulation have suffered greatly. Here in the South, we have a saying that certainly applies to this situation: "If it ain't broke, don't fix it" Please withdraw this proposal immediately for the good of our clients.