Subject: File No. S7-14-08
From: Michael D Allen
Affiliation: LUTCF

July 10, 2008

I hold both an insurance and securities license. Up until about one year ago I did sell indexed annuities but then my Broker Dealer informed me that I could no longer sell outside of their seeing agreements with selected companies. The Broker Dealer offered very few products and can't even provide marketing support for the products. In my opinion the securities industry is attempting to gain revenue from a product that currently is a better option for much of the general public than the mutual funds they are offering. It appears to me that if they can't provide marketing support then the public will be the long term victim, not the securities company.

From my experience, people who consider an indexed annuity are frustrated with security types of products and are seeking an alternative to that. The indexed annuity does that. It offers stability that variable and equity based products can't.

I'm concerned that the securities companies are simply swinging their weight attempting to gain control and increase their revenues more than approaching this from a consumer approach.