Subject: File No. S7-14-08
From: JAMES P BANKS, MR

September 16, 2008

This proposal is simply a power grab. The insurors have been issuing a safe alternative to the choices available to people from the risk-laden equity markets.

The insurance companies are far more careful with the public's monies than are the large broker-dealers.

This proposal is prompted by a dishonest outcry from said broker-dealers out of jealousy that the insurors have made inroads into their sandbox. NOTHING MORE than the fact that the insurors have built a safer, better product.

When the brokerage industry invented universal life insurance, the insurance industry did not cry foul it embraced universal life concept and improved on it.

To mischaracterize fixed indexed annuities as securities would be turning the hen house over to the foxes.