Subject: File No. S7-14-08
From: Donald L Unger

September 2, 2008

Considering Fixed Indexed Annuities, I would like to express my view that 1)since an investor has no risk of loss to their invested principal due to stock market downturns, and 2) considering that there is a guaranteed death benefit, and 3) since the client can elect a guaranteed lifetime income stream, all features unavailable in traditional equities or bonds- that they can not and should not be considered investments under the jurisdiction of the SEC. I believe that the state insurance commissioners can adequately continue to supervise FIAs.