Subject: File No. S7-14-08
From: David J DArcangelo
Affiliation: former Public company President

November 4, 2008

I totally disagree on the proposal to make fixed index annuities and related productsa security. This is a simple insurance company guarantee product.

Training is the answer for financial products by agents. Training is so widespread now and effective in the industry there is no need for the SEC to regulate a simple guaranteed insurance product.