Subject: File No. S7-14-08
From: Marshall S Wise
Affiliation: CEP

July 1, 2008

Dear Rule Making Committee,

I am writing to you regarding the proposed S7-14-08.

Fixed indexed annuities are guaranteed never to lose principle which is not considered an investment.

Please do not consider these "fixed" annuities as securities. This regulation will further confuses the general public of what exactly is the definition of an investment vs. a savings plan

Thank you for your attention to this important matter.

Sincerely,

M. Wise