Subject: File No. S7-14-08
From: William E Johnston, Jr

July 16, 2008

Thank you for the opportunity that allows me to comment on the intrusion of the SEC into the fixed indexed annuity market. I was a certified Series 6 registered representative for 20 years. In that time I watched the SEC and NASD become more micro-managing, and maker of more useless rules than I could have believed possible. I do not think that either institutions have made the investment market better. If anything--in my opinion, they have made the business they were supposed to be regulating into a quagmire of rules that are unclear, obtrusive and generally cloud the issues they are supposed to shed light upon. I cannot believe that by putting the Fixed Indexed Annuity market under their dominion will help anyone but those churning marketeers who carry certifications to sell them. SEC nor NASD want to protect the people who buy these products, they want to capture the market so that the few will feed on the food of the many. In a business as unstable as the stock market you only want to dominate the FIA market for a safe haven to move your bad investments into, so rather than sharing the cake with others you opt to take it all in an underhanded strike upon the life insurance industry. If the investment markets were going like "gang-busters" you wouldn't care about the FIA markets, but since they aren't you cast your eye upon the life insurance market in hopes of taking a stable, safe, risk free product away from them and making it your own. Truth is, all you have to do is give your agents permission to sell FIAs like they were doing a year or so ago. Since you make your own rules up, why not change them to accomodate your brokers and R.R.s? Because you don't want the competition.
I hope this dog bites you. Hard