Subject: File No. S7-14-08
From: Paul D. Tomasula
Affiliation: Registered Investment Adviser

October 21, 2008

RE: 151A

I do not think it a good idea to consider Index Annuities to be investments and require a securities license to sell or market them.

For the most part, I believe that they are related to investment indexes similar to the way whole life policies are related to the bond market.

The broker who sells them has no influence over the outcome in the way a mutual fund sales perzon or stock broker has.

Moreover, if you will notice, the market has declined a great deal over the last 12 months and traditional investors in the equity markets have suffereed trillions of dollars of losses. On the other hand, Indes Annuity owners have not. How are Index Annuities like an investment if you cannot take a market loss?