Subject: File No. S7-14-08
From: Corey B Zimet

September 8, 2008

Indexed Annuities are fixed annuities that like raditional declared rate fixed annuities, guarantee the principal and guarantee a minimum interest rate but provide the opportunity to earn interest credits in excess of that guarantee. An indexed annuity provides the opportunity for these excess crdits based on the measurement of an external stock index or bond index. Both of these options result in fluctuating levels of the annual credit however in both cases the consumer has no risk of loss of premium or prior interest credited.
2. Bo the design and sale of these fixed indexed annuities are highly regulated b each state insurance departments as are the companies who manufacture and sell them. State insurance regulations cover sujitability of insurance agent recommendations, annuity disclosure, advertising, agent licensing , training, unfare trade practices including misrepresentation of product terms and conditions and enforcement actions and penalties for noncompliance with sales practice requirements. In addition, guaranteed minimum values for annuities are regulated through the Standard Non- Forfeiture Law and are applicable to all fixed annuities.