Subject: File No. S7-14-08
From: Dee Costa
Affiliation: Sr. Vice President, Sales

September 11, 2008

1. The SEC suggests that a fixed indexed annuity (FIA) is purchased for essentially the same reasons people purchase mutual funds and variable annuities. In my experience they are not. FIAs are purchased as savings vehicles due primarily to the safety they offer and not on account of any actual or promised rate of return.

2. The SEC suggests that FIA purchasers somehow shoulder investment risk for fluctuating market performance, yet no losses can be experienced if and when the product is held to maturity.

3. The SEC argues that there will be increased competition by adopting proposed Rule 151A. However, my extensive communications with insurance agents and financial advisors concerning it suggests exactly the opposite. If adopted, only consumers who open brokerage accounts may access an FIA.

4. After seeing the devastation of my mother and my aunt's retirement income plummeting in early 2000 with no time to recover, I stand firm that folks in retirement and those planning for retirement need savings instruments with principal protection and guarateed income streams, as provided by FIAs.