Subject: File No. S7-14-08
From: Michael P Thurston

September 2, 2008

In my opinion, Indexed Annuities should NOT be classified as a Securities product for the following reasons:

1. With Indexed Annuities, there is no risk of loss of principle, like with a variable annuity. Because there is no risk of principle, Indexed Annuities are more akin to Fixed Annuities than Variable Annuities. Therefore Indexed Annuities should remain a non-securities product.

2. Client monies are NOT actually invested in the market, gains are only based on the performance of the respective market induces. Index Annuities just do not meet the definition of a product that requires a Securities license.