Subject: File No. S7-28-07
From: WILLIAM h HARKINS, mr.
Affiliation: NATIONAL ASSOCIATION OF INSURANCE AND FINANCIAL ADVISORS

September 5, 2008

TO THE SEC AND INTERESTED PARTIES:

I HAVE BEEN SELLING ANNUITIES FOR OVER 30 YEARS. I STARTED
MY CAREER AUG. 1, 1974.

THE INDEX ANNUITY HAS BEEN A GREAT TOOL BECAUSE MY CLIENT
DOES NOT HAVE TO SUFFER LOSS OF PRINCIPAL IF AN INDEX
SUCH AS THE STANDARD AND POORS 500 INDEDX(SP)DOES GO
DOWN. THE CONCEPT GIVES A GREAT DEAL OF STABILITY TO
MY CLIENTS BECAUSE THEIR VALUE MAY ONLY GO UP, NOT DOWN.
DURING A DOWN SP YEAR YOU DON'T LOSE, BUT SIMPLY DON'T
MAKE MONEY. WHEN IT'S UP YOU GET CREDITS.
THE VERY MOST IMPORTANT THING FOR THE CONSUMER IS
THEY HAVE AN EXTREMELY HIGH SAFETY THRESHOLD, PLUS THEY
HAVE MONEY AVAILABLE ANNUALLY, MONTHLY, AND IF THEY
ARE TERMINALLY ILL OR NURSING HOME CONFINED THEY ALLOW
ACCESS. MY CLIENTS CONTINUALLY TRAVEL, ENJOY THEIR MONEY,
PASS IT TO THEIRS AIRES AND ARE SATISFIED.
I WOULD LOVE TO ANSWER ANY QUESTIONS ABOUT THESE WONDER-
FUL PRODUCTS. SINCERELY, WILLIAM HARKINS 817-292-6135.