Subject: File No. S7-14-08
From: Richard W Schank, CFP, CHFC, CLU, CFS, RHU, REBC, EA

July 10, 2008

I think it is about time these products are categorized as a security. Lordy be There are called "Equity" Indexed Annuities, at least they were until they changed the name to Fixed Index Annuities. What a scam, changing the name of something doesn't change its nature.

The product is based on participation in an underlying index, usually the SP 500 and is hedged with options. What about that doesn't sound like a security???

I know of many a situation where people were misinformed, either intentionally or not, and didn't get what they thought they were getting. These products need to be regulated more closely by someone other than the company that is selling them.

I appreciate the proactive stance that the SEC is taking. Not knowing how the product is categorized is a disservice to the public and reps. The uncertainty was very disconcerting for those of us who want to represent products clearly.