Subject: File No. S7-14-08
From: Tony Bianchi
Affiliation: Life Insurance Agent

September 8, 2008

Indexed Annuities are fixed annuity products.

Consumers view them more as an accumulation/savings vehicle than an investment because of safety of principal.

The current regulation of indexed annuities under insurance law has not been a problem that needs a fix. The status quo is working.

Classifying indexed annuities as securities will reduce competition and hurt consumers.