Subject: File No. S7-14-08
From: richard d power

July 9, 2008

The FIA is in NO way like securities, variable annuities or mutual funds. There is NO downside market risk and there ARE guarantees so that any principle amount deposited and any gains made will NOT be lost, unlike other securities products.

Please do not put FIA's in the same category as investments in ACTUAL SECURITIES. Many people have LOST there initial investment and in some cases lost their life savings in actual scurities.

This can not happen with a FIXED INDEXED ANNUITY BECAUSE IT IS NOT A SECURITY.