Subject: File No. S7-14-08
From: David V Crump
Affiliation: President, Employee Benefits Consultng Company

August 13, 2008

This rule is a bad idea.

Fixed and Indexed Annuities represent a helpful conservative long term wealth accumulation product combined with the insurance and Security of lifetime income options not found elsewhere.

Millions of non registered insurance agents have provided access to these products for regular customers that don't have the requisite $100K that most stock brokers are looking for. When cases of excessive abuse do come up, insurance companies are more than willing to cancel the suspect contract and return the funds. Additionally, the IMSA has made great progress in the area of proper marketing and information disclosure about these products.