Subject: File No. S7-14-08
From: Mark G. Demers

October 29, 2008

I would like to strongly oppose this ruling. What has changed to make index annuities a security? They are a safe place for people to put there dollars. They are not invested in the market. If the market goes down there is no loss. They have a gauranteed rate of return with a rider attachment and give the people a sense of security because they know their money is safe and can't go down in value from a drop in the market. I urge you to take this ruling off the books. It is already highly regulated by the state insurance commisioners and have stringent suitability requirements - even more so than if somebody would invest with a broker. It does not make sense to adopt this ruling. I know the mutual fund money managers and brokers are losing some commisions because people are moving some money to index annuities for safety but if that is the reason to change the law - it is not right.

Sincerely,

Mark Demers