Subject: File No. S7-14-08
From: Thomas F Powell

October 14, 2008


I firmly believe the Fixed Index Annuity is an insurance, because the customer has gauantees against losing any principal unless they themselves break the contract.
The index portion of the contract is an outside venue whereby the customer is able to capture a portion of the upside of any market change with no loss potential.

The is totally different from any security on the market.
Even variable annuities that you now supervise has the potential to loose principal and thereby should not be marketed as an ANNUITY.