Subject: File No. S7-14-08
From: Gary T. Kunishima

July 14, 2008

I strongly oppose the SEC's contemplation of making FIXED indexed annuities as "securities".

Fixed indexed annuities are guaranteed not to lose the annuitant/investor any money as long as he/she abides by the terms of the contract, i.e., does not take premature withdrawals.

Purchasers of fixed indexed annuities are, generally, those who have retired or are soon-to-be retired and cannot afford ANY LOSSES as is possible with securites, i.e., stocks or mutual funds.

By classifying fixed indexed annuities as "securities" the SEC will be hurting, rather than helping, those investors who are retired or soon-to-be retired.