Subject: File No. S7-14-08
From: Aaron A Cook
Affiliation: CiB Professional Insurance Advising

October 31, 2008

To whom it may concern,
Index Annuities are clearly not investment products, and return a fixed rate to the consumer. If the argument is made that you can lose money due to surrender charges than certificates of deposit could fall under the same umbrella.
If I did not know better I would assume that index annuities have been such a success that the securities market feels somewhat threatened by their growth and would like to have them under their control. They are clearly not securities, but they do provide a viable alternative for someone who is risk adverse and would like a chance to outpace inflation.
Please allow the public to have easy access to a product that has a viable place in some peoples portfolio.

Thank You,
Aaron Cook
CiB Professional Insurance Advising