Subject: File No. S7-14-08
From: Elizabeth J Reppen
Affiliation: Financial Advisor

October 29, 2008

To Whom it May Concern:

The daisy chain of debt defaults set in motion by the collapse of the 1920s bubble caused 15,000 banks to fail between 1929 and 1933, which lead to the Great Depression. So the Glass-Steagall Act of 1933 was passed to deal with this and prohibited investment banks from again acting as commercial banks. No longer could investment banks (which make speculative bets) own commercial banks (which accept savings deposits from customers) and thereby risk the savings of depositors.

This act was repealed on 11/12/99 by the the Gramm-Leach-Biley Act which now allow commerical and investment banks to consolidate. Some economists have criticized the repeal of the Glass-Steagall Act as contributing to the 2007 sub prime mortgage financial crisis.

Hundreds of my clients invest in insurance companies with the goal in mind of the added security and protection that securities don't provide them. So to have index annuities labeled as securities would scare my clients away from investing in them. I do not in any way want to have Index Annuities considered as securities and any way linked to the losses that are now occurring in the banking and securities industries.

I am securities licensed and if my clients wants securities, I sell them securities and when they don't I sell them Insurance products (Annuities) therefore I hereby request that you do not go forward with this misnomer as it would be a grave mistake.

Sincerely,
Elizabeth J. Reppen