Subject: File No. S7-14-08
From: DONALD W OWENS
Affiliation: MEMBER, INTERNATIONAL ASSOCIATION OF REGISTERED FINANCIAL CONSULTANTS

August 22, 2008

-The SEC has either a novice understanding of how Fixed Index Annuitys work or is not concerned enough to learn how they work. Never at any time is there any greater risk to the consumer that in any other Fixed Annuity.
The same guarantees are offered by the issuing company's
for both products. Safety of the Insurance Company's guarantees are why seniors buy Index annuitys.

The states have done an excellent job of revising the compliance issue relating to suitability. The insurance companies have gone to the extreme to make sure the consumer purchase is appropriate.

If the SEC were to take control it would be the same as an over the counter purchase of a band aid requiring a prescription from a doctor. The consumer is the one that would pay the price for this poor decision.

The SEC should instead look into the Reckless way brokers place Senior Consumers into mutual funds, Stocks and Variable Annuitys in which they lose their life savings. There are plenty or places they could serve the public if they would start to police brokers that already fall under their jurisdiction. These are the rules that need to be modified. Taking away the availability of the safety conscious consumers ability to purchase a fixed annuity
without seeing a broker will lead to the broker pursuading them to buy a risk product and potentially loose their money. Is this what you really want???
This is a CRIME.