Subject: File No. S7-14-08
From: David J Yoder

October 27, 2008

My understanding is that the returns in my annuity are not the same as the stock market, but only that they are BASED on stock market ups and downs. In the stock market, I can lose money in my annuity, I cannot lose money. The worst scenario is that I have zero growth, which is definitely not the worst scenario in the stock market. And, I could allocate my annuity to FIXED if I want to ensure some growth don't have that option in the stock market.

Indexed annuities vs. the Stock Market -- two VERY different investment avenues. One offers potential growth based on the reflection of the stock market activity while the other offers potential growth or loss in the stock market.