Subject: File No. S7-14-08
From: Pamela Stephenson
Affiliation: ValuTeachers

October 22, 2008

As a licensed insurance agent I would like to express my belief that the equity-indexed annuities not be treated as securities but continue as insurance for the following reasons.

Equity-Indexed Annuities meet the saving needs of the public
They are NOT high risk, the principal cannot be lost
They offer guarantees of premiums paid and interest credited
Risk is virtually the same as a traditional fixed annuity
Proper supervision for traditional fixed annuities, indexed annuities and life insurance is being performed according to state insurance department rules. This oversight is working well

Further the measure would cause the loss of jobs for many individuals and small businesses and companies across this nation. In these hard economic times the loss of income for individual cannot be substantiated.

The Equity-Indexed Annuity has proven to be a safe, valuable and successful form of retirement savings with a proven track record.

Thank you
Pamela Stephenson
ValuTeachers