Subject: File No. S7-14-08
From: Paul R Larson, CEP

October 20, 2008

-I feel this ruling on Index FIXED Annuities is totally off base and should be stopped or re-desigined in some way to not fall into the variable product market---Clients aren't buying shares of stock-- the insurance Co. is in the futures market--this a insurance product not a Brokerage account ----- the down side risks invovoled are much differant then pure investment type accts. Many insurance agents are not in the variable sales world and should be able to bring this type of FIXED Annuity concept to their clients --without series 6 licensing--even NOW more then ever with the what Wall Streets greed has done to the Stock Markets