Subject: File No. S7-14-08
From: Dorothy Albala
Affiliation: NAIFA

October 29, 2008

If the SEC would take a closer look at these products, they will understand they are fixed with guarantees attached.

That is not something that can be touted in an equity based product. Therefore, it is not a true "stock" product, since there is no volatility.

This bill should be thrown out