Subject: File No. S7-14-08
From: Nick Pino, Jr.

September 10, 2008

Indexed annuities are fixed annuities that guarantee a minimum interest crediting rate and provide the opportunity to earn interest credits in excess of that guarantee. Annuities are highly regulated by state insurance departments. Many states have already adopted NAIC Annuity Disclosure Model Regulation most of the annuity carriers have mandated the use of disclosure statement describing all important terms and conditions of the annuity contract, including disclosure of surrender charges.
Please do not make any changes as the annuitants are already protected by each state insurance department.
Thank You.
Nick Pino, Jr.