Subject: File No. S7-14-08
From: Francine Keys

September 2, 2008

I have found that the Fixed Index Annuities have proven to be the life saver for my clients. We do realize and recognize that in times as these we do want to have the availability to decide whether or not we want to invest our future in a protected arena. I have the experience of seeing retirement money placed in this safe arena and see the companies providing the Annuities are solid and are insurance products and not a market risk security. All of the clients I have were totally displeased with the market risk and feel confident with the annuities. We look forward to the opportunity to continue to provide services from a agent level with this market.

Thank you,

Francine Keys