Subject: File No. S7-14-08
From: Terrell D Harris
Affiliation: President of Harris and Assoc., Inc.

October 14, 2008

Dear Sir:

Please leave the state in charge of the watch dog role over index annuities. The state is doing a much better job then the SEC would do. I have seen much improvement in the way the state is handling this matter.

Sincerely,

Terrell D. Harris