Subject: File No. S7-14-08
From: Eldon C Williams, CLU
Affiliation: AXA-Advisors

October 14, 2008

The Securities and Exchange Commission or FINRA does NOT have any business regulating a FIXED INSURANCE PRODUCT. The state insurance department should oversee the quality and cunsumer worthiness of all insurance offered in their state. I believe the answer is a stated minimum standard, with the heart of the standard being based on a quality consumer product, for all states to accept on insurance products. Bottom Line: The Indexed Annuity is not a securities product. Let's EDUCATE not ADJUDICATE.