Subject: File No. S7-14-08
From: Bruce B Bamford
Affiliation: LUTCF

October 20, 2008

I believe Indexed Annuities should be a securities investment.
I have personally attended many trainings on them and came to the comclusion, they are truly extremly hard to understand and if an agent can pass the series 6, then take many online courses to pass a special exam to sell them, then our Seniors are a lot better protected.
I truly believe they are extremly missold by fixed insurancec agent and all the companies selling them are complaining only because of the loss of revenue, not for the protection of our seniors in fighting this possible ruling.
Make them a securities product, please.