Subject: File No. S7-14-08
From: John Rocco

October 21, 2008

Re Proposed Rule 151A:

Indexed Annuities, by definition, are fixed, guaranteed products. They are NOT stocks. Investors cannot lose principal, unlike variable products.
In this time of massive losses in the stock markets, the public is demanding safe investment havens. To have the SEC declare Indexed Annuities a security would only confuse and frighten them away from one of the safest places for their retirement funds.