Subject: File No. S7-14-08
From: Kevin Nay

July 14, 2008

I do not believe that indexed annuities should be considered securities by FINRA. They have minimum guarantees, and no downside risk.

Thanks for your time

Kevin Nay

Advantage Benefits Financial and Insurance Services
1111 E. Tahquitz Canyon Way, Ste 121-2
Palm Springs, CA 92262