Subject: File No. S7-14-08
From: Craig J Cohen

September 10, 2008

It is my opinion that to group indexed annuities with equities securities and variables is the same as grouping life insurance with equities. It makes no sense. Selling stocks, bonds, other equities, and variable annuities these products put the consumer at risk and in fact should place more of a burden on the agent to ensure that when selling these, that much more prudence and care is taken. Indexed annuities are not at risk. They in fact act as a long term savings account similar to any other savings program. The only area at risk may be the insurance company and even that risk is so miniscule it's not worth mentioning . The indexed annuity grows conservativly and does not put the customer at risk. The funds are not at risk, and selling them although critically important to know the ins and outs of them, is not the same as selling an equity, a bond, or a variable annuity. They indexed annuity is not at the whim of the ups and downs of the stock market or any other market therefore although suitabity is a concern and critically important, since the investment cannot be lost due to a down market, I for one ask that you do not group them with investments that are at risk, as you do not group life insurance as an at risk product