Subject: File No. S7-14-08
From: Steven H Minnich

October 28, 2008

Annuities that are indexed to the stock market without the funds being deposited IN the stock market are a perfect solution for clients that want to have the potential for better returns (with a cap) while at the same time enjoying the comfort of a guaranteed floor. Those of us who are "fixed only" licensed prefer guaranteeing our clients that none of their principal will be at risk in any way. "None of my clients have lost any money in the stock market" is a powerful and very comforting statement.

Is it possible that we have created such an outstanding financial tool that securities licensed agents are "jealous of the competition? They can already sell either variable or fixed products. Why take away the meat and potatoes of other agents.

Perhaps the series 65 license could be required for indexed annuities in as much as that is somewhat of an in-between license and this financial tool is also somewhat in-between the fixed annuities and variable annuities. There is enough unrest in the financial services industry as of late. Why would we want to add even more grief to agents that are calming the fears of clients across America?