Subject: File No. S7-14-08
From: Terrence Judy
Affiliation: Registered Nurse and Licensed Insurance Professional

August 1, 2008

To whom it may concern:

I am greatly concerned, frankly, quite mystified that the SEC could in any way construe FIXED Index Annuties to be securities and therefore, in need of FINRA oversight. These are INSURANCE products and they have been available for years to conservative savers who have NOT lost a dime of their assets due to the downturns in market performance that cause real securities to lose value. FIAs in general offer very real principal deposit and growth guarantees to their owners that stocks, mutual funds and variable annuities by their nature cannot and they do so under the jurisdiction and protection of each state's insurance commission. Please do your homework on this.
The only logical reason for the SEC's interest in this matter is money specifically the 26 billion dollars of FIAs that were purchased in 2006 alone. It stands to reason that this money had to come from somewhere - it came from money-losing stock and mutual fund accounts. Savers got tired of watching their nest eggs wither and shrink as they got closer to retirement. The insurance industry responded with an exceptional alternative for retirement and long-term savings plans. The FIA. It delivers the guaranteed growth and security that is neccessary for a balanced savings strategy. And while some would argue that the one-time agent compensation for these products is too high and unfair to the consumer let me ask this - how is it fair that securities brokers get ongoing commissions regardless of whether their clients accounts make or lose money? Who is bringing real value to the table?
There are plenty of appropriate safeguards in place in the insurance industry with regard to the FIA to protect the consumer. Please disregard proposal 151A and encourage securities salesmen to do a better job of keeping their clients satisfied.