Subject: File No. S7-14-08
From: Dee Ann Davis
Affiliation: Licensed insurance agent

September 2, 2008

I have been a licensed insurance agent for 26 years and work very hard to do the best job I know how for my clients. Their best interests are always considered first when I discuss their needs for placing their monies into a secure product, such as fixed, indexed annuity.

I am not a stock broker, nor do I have any interest in becoming one. I take a great deal of pride in my profession and in the way that I treat my clients and don't see why the SEC would feel that they have the right to place restrictions on the way I help my clients.

Indexed annuities are NOT SECURITIES and were designed for protection for the client, not for speculation in a risky investment. Therefore, I would appeal to the intelligence of those who are trying to make them into what they are NOT. Read the definition of a fixed annuity. It is not a security.

PLEASE, DO NOT PLACE A FIXED, INDEXED ANNUITY INTO THE SAME CATEGORY AS A RISKY INVESTMENT IT IS NOT AND THEREFORE, THE SEC SHOULD HAVE NO SAY CONCERNING THEIR SALE.

Thank you for listening to my earnest plea for common sense in this matter.

Sincerely,
Dee Ann Davis