Subject: File No. S7-14-08
From: Derek Gibson
Affiliation: Insurance Broker

September 3, 2008

I do not write alot of indexed annuities. I do not however think that it is fair for you to say that I have to have a securities license to sell a product that is not directly tied to the stock market that someone can not loose any of their principle investment in so long as they stick to the terms of the original contract. Are securities licenses required for someone selling certificates of deposit against bank debt? No... I was tested by the state on annuities when I went down and passed my licensing exam and according to the state that is sufficient. But once again let let the government step in and make a mess out of something they once again know nothing about.