Subject: File No. S7-14-08
From: Merlyn C Javier

September 5, 2008

I have been marketing Index Annuities for the past 10 years and had been matching ones that are best suited for my clients' needs. So far, only 1% had dropped out of the program which tells me the approval rate is good.

I happen to know that security products do not have better tract record after all the charges so I can not see the rationale of giving registered representatives the monopoly of marketing the index annuities because of one bad apple.

It will leave me with one less product to market which happens to be a significant part of my livelihood in this upside down economy.

Sincerely,
Merlyn Javier