Subject: File No. S7-14-08
From: Olin L West, MD

July 14, 2008

Fixed Indexed Annuities (also known a equity indexed annuities) are clearly not securities. The original moneys put into the annuity is guaranteed by the insurance company to never go down in value. The same is true for whatever annual gains that get swept into the annuity account value. The only way that the annuity account can go down in value is if the owner takes money out of the account to spend it. Such products are savings instrument and certainly do not need SEC oversight.