Subject: File No. S7-14-08
From: Mark G. Demers

September 1, 2008

I would like to make a comment that index annuities are fixed annuities. They gaurantee a minimum interest credit rate and provide and opportunity to earn more interest in excess of that gaurantee. There is no risk to the consumer. Both the design and sale of these annuities are highly regulated by state insurance departments. I fail to see that this could be labeled as a security.

Are you getting pressure from FINRA to do this? Is somebody getting paid off? This makes no sense to change an existing law to accomodate FINRA'S whims.

I would ask that you reconsider this absurd proposed rule.

Sincerely,