Subject: File No. S7-14-08
From: Dwight K Walker
Affiliation: Financial Advisor

July 11, 2008

-If the product says "equity" treat it as an equity. If it is an insurance product call it a "Variable Rate Annuity, based on ________"(SP 500 or whatever index)Performance. The product is not as easy for clients understand as the insurance companies or their agents proclaim and many agents do not understand the product well enough to properly explain and disclose it either.