Subject: S7-14-08

August 27, 2008

I'm a member of NAIFA and they do a lot of good in the industry; however, on the issue on including index annuities in the security category, I believe NAIFA is off base. NAIFA recommends that its members oppose this legislation. I applaud the legislation and encourage and urge you to regulate indexed annuities like a security. There are way too many agents in the field that are simply ripping off the elderly with these annuities and it needs to stop.

Thank you very much.

Richard D Lamberson, FICF, CSA, CLF
Managing Partner
Modern Woodmen of America