Subject: File No. S7-14-08
From: Mark E Rauguth
Affiliation: Financial Advisor

October 20, 2008

I believe that equity indexed annuities should be a security and goverened by the SEC. They have a component, and one the invester doesn't understand or is not explained to them, that is tied to the stock market. Subsequently,there is risk and costs associated with this. The way it is structured now, too many investors are being taken advantage of and the system has to be monitored and policed. I vote to make it a security