Subject: File No. S7-14-08
From: Timothy Warnock

November 3, 2008

Dear Sirs,

I am writing concerning the proposed requirement for life agents to be series 6 or 7 licensed to offer equity annuities. I am opposed to this requirement for life agents for the following reasons:

1) Equity Indexed Annuities have guaranties that are identical or similar to fixed annuities.

2) Holders of Equity Indexed Annuities, myself included, have not experienced any loss of principal nor can they loose principal apart from surrender fees for early withdrawal, just like fixed annuities.

3) Consumers will have less access to a good financial product if they are only offered through securities firms.

4) Life agents currently must complete bi-annual continuing education to offer annuities including Equity Indexed Annuities.

In conclusion, this is a product that I have offered to my clients for the past 11 years. They have enjoyed great returns on their premium for many years and have not lost money even in this current economic and stock market downturn. I weigh in as someone who has marketed Equity Indexed Annuities to over 200 satisfied clients. Your proposal would eliminate my ability to Service these policy holders or offer it to other consumers.

Thank you for your consideration.

Sincerely

CA agent, Tim Warnock
Life # 0596836
(209)579-1149