Subject: File No. S7-14-08
From: Ronald C Wiitala

October 21, 2008

I don not believe the Equity Indexed annuities should be governed under the SEC. The State Insurance Commission currently has jusisdiction in this matter and has with coperation with Insurance Companies have updated suitability forms along with full disclosure about the Insurance products being offered.

Your original-151A proposal was partically based on the Dateline show which diplayed biais one sided view on Insurance agents - quote "selling Insurnace products".

These index products are a suitable safe option for safe preservation of assets. These are fixed annuities, wherre you can not loose your principle. Ther is no direct investment in market " no risk" your funds can not go down if market goes down.

I agree that full disclosure on insurance products must be made. Yes these fixed annuities have surrender charges if you take withdrawels typically over 10% annually. This fact must be made clear -- full disclosure is rerquired

These annuities can be a great place for retirees to position their IRA dollars to keep them out of market risk - making sure that they don't loose their etirement savings due to a market correction -- like the on we have just seen.