Subject: File No. S7-14-08
From: Don W Rausch, Jr.

July 10, 2008

I support this rule. Each investor has their own reasons for purchasing individual investments. Cost, access to principal, participating rates, surrender charges and most importantly suitability should all be considered by a qualified professional. Access to equity markets through investments even indexed annuities should be subject to the same rules that currently exist. I disagree with comments that rates are generally cheaper over the life of the contract. Unfortunately the large majority of people selling these products are not the clients primary planner.It is do to this that the client receives no service or assistance from the person selling this product. Many clients are also told that they should surrender VA's to purchase Indexed Annuities without an understanding of living benefits, withdrawal benefits, or the overall financial plan that may be dependent on the VA's benefits. The client that invests in Indexed Annuities may be better suited for a well diversified rebalanced portfolio of mutual funds taking advantage of breakpoints. A professional should determine this not a salesperson.