Subject: File No. S7-14-08
From: Edward A Pickard
Affiliation: Public Accountant

October 20, 2008

-Indexed Annuities are the safeguard for the average person who is looking for a secure retirement. With the overall uncertainty in the market and the lack of proper supervision by the SEC and NASD, the public is well served by the Life Insurance industry with the Indexed Annuity products.