Subject: File No. S7-14-08
From: James R Beach
Affiliation: Executive Director, First American Funding

July 7, 2008

With due respect to the marvelous job the SEC does to protect consumers, it seems a rather large leap to extend its oversight to fixed indexed annuities.

It seems odd to me that this type of rulemaking typically occurs when 1) a product outside the purvue of the SEC becomes popular 2)the stock market isn't doing particularly well.

The insurance industry has already added layers of consumer protection, disclosure and suitability to indexed annuities that borders on trying to convince the consumer to do nothing. That's the safest tactic it seems. Plus, with an insurance commissioner in each state regulating both companies and agents, where's the rampant wrongdoing?

I do not think the SEC should add to it.