Subject: File No. S7-14-08
From: Robert W Finberg
Affiliation: Certified Retirement Planner

July 23, 2008

Indexed annuities are not securities as everyone knows. They are fixed annuities backed only by the strength of the insurer who issues the contract. There is no possibility of short or long term loss in value as with variable annuities unless the insurer in fact cannot meet their obligations. The only reason regulators want to classify fixed indexed annuities is there are unscrupulous sales agents who do not make full disclosure of costs, expenses, risks and features.

Those individuals should be forever banned from holding a life insurance license and it's the State's responsibility to regulate and monitor sales agents.

Please reconsider that fixed indexed annuities do not need further regulation. It's up to the State licensing departments to regulate the sales agents.
Sincerely,
Robert W Finberg
a licensed agent since 1969 in California