Subject: File No. S7-14-08
From: neill a atkins

September 2, 2008

I encourage the SEC to consider Index Annuities as securities and properly regulate the product.

The product is a complicated annuity that has not in many cases been explained properly to prospective annunitiants.

The annuity is based on stock indexes and has been sold by insurance agents in many cases who are not series 6 or 7 licensed and who may have a lack of understanding the product themselves.

This is long overdue.