Subject: File Number S7-14-08

August 28, 2008

Florence Harmon
Acting Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609

Florence Harmon:

I am a member of NAIFA Wisconsin and I disagree with their view. I think indexed annuities are sold very improperly today and making them a security would eliminate the major amount of improper sales and would force life insurance agents to get education to learn what they are selling.

Allan Hibbard
Registerd Rep

Sincerely,

Allan Hibbard