Subject: File No. S7-14-08
From: Patricia G Leonard

September 6, 2008

I do not believe that fixed index annuities meet the definition of securities. I realize the goal of this proposed regulation is to protect consumers from unscrupulous agents, but I do not feel this is the answer. I think agents should be required, at the state level, to undergo additional training on fixed index annuities if they wish to sell that product, but I think requiring agents to obtain a securities license is going too far. Labeling index annuities as securities is not the answer.