Subject: File No. S7-14-08
From: VINH Q Nguyen, MBA
Affiliation: Teaching Associate, California State University of Hayward

September 2, 2008

To SEC:

I strongly oppose that the Index Equity Annuity should be considered as Security. This is because:
1. IEA does not participate directly to stock market
2. Does not loose value on the volatility of the market.

Please reconsider the rule 151A to reduce the enforcement efforts.

Regards,
Vinh Nguyen