Subject: File No. S7-14-08
From: Dan B Grimes
Affiliation: Marketing Director

September 5, 2008

My only comment is regarding the current lull in the stock market. FIAs have "insured" the people that bought them during this downturn. While many in the stock market have lost 25% of their nest-egg, those with FIAs will not participate in this correction. That is Insurance. That is what insurance is and that is what it is used for.