Subject: File No. S7-14-08
From: David P Smith, MPA

July 7, 2008

The SEC is overreaching their stated authority. Unlike security products The Fixed Indexed Products are regulated and principle guaranteed by the insurance company. None of the SEC's Stocks Bonds or Mutual Funds provide a guarantee of principle that the insurance company provides their clients. This is guaranteed through state regulations -- not federal. If the feds wish to get into this area they need to put up the capital to provide guarantees that they fail to provide to protect the public with currently on their heavily regulated products---products which many people lose their principle all the time.
The SEC has no Jurisdiction. Yes they want the control and not the responsibility. They want to control and damage a industry that provides a service that they don't understand. The insurance industry is about GUARANTEES so clients don't lose their shirt. The SEC has no background or understanding of this market. For them to get their nose into it will damage the savings and retirements of millions of americans that want nothing to do with risking their principle on a gamble on the stock market.