Subject: File No. S7-14-08
From: Mark A Wilcox
Affiliation: CEO WFS Inc.

October 21, 2008

SEC regulation of index anuities is a duplication of existing state regulation. Futhermore SEC regulation is not complete due to regulation of only the index portion of the contract. Ultimately this is a guaranteed investment without market risk.

The use of an index no more makes this type of annuity an investment than using a bank rate index would make them a CD. (bank certificate of deposit)

Mark Wilcox