Subject: File No. S7-14-08
From: Nancy P Rupert

October 22, 2008

As a long term professional insurance advisor, I would appreciate your consideration of my comments regarding the changes being suggested to the insurance company availability of indexed annuities.

During my 30 years as an insurance agent, it has been my personal choice to not maintain a securities license. The main focus of my business is involved in wealth management of seniors and pre-retirement planning. Since the majority of my clients do not have the time to recoup any losses to their investments, I do not need to provide them with investments that are governed by the SEC.

The indexed annuities that are offered by reputable insurance companies are a safe, responsible option for retirees to participate in stock market gains with no risk to their principal.

I see absolutely no reason, other than the greediness of the brokerage industry to take away the option of an insurance agent to be able to offer the indexed annuities to their clients.

As a licensed agent, I take very seriously the recommendations I make to a client and do not feel the need to hold a securities license and incur all of the expenses and reporting ruqirements involved to offer a fixed insurance company option.