Subject: File No. S7-14-08
From: Billy J Bailey
Affiliation: Life Insurance Agent and Annuities

November 3, 2008

I have been an agent since 1966 and strongly oppose the rule that would adopt all fixed index annuities as securities under the Securities Act of 1933.

In fact I had my Series 7 and Series 63 and gave these up because I did not want to sell variable life. I do sell annuities and indexed annuities and you should not take the ability away from me or any other agent. Fixed index annuities are not to be considered securities.

Thank you.