Subject: File No. S7-14-08
From: john j duddy

September 3, 2008

I have been in the insurance business for over 34 years. During this time I have been a registered representative and a registered investment advisor, up until just the last 2 1/2 years. I strongly feel that equity index annuities are only insurance products and are not securities and therefore should not be regulated by the state as well as the SEC.

The public is protected when professional salespersons take the time to make sure that the product they recommended is SUITABLE for the client. This is where the protection lies not in additional regulation which generally is ineffective anyway.

In my opinion the broker-dealers and the banks are behind this "additional regulation" since they are the ones who most benefit by it.

How about serving the public and not listening to these special interests group for a change.

Most sincerely,

John J.Duddy