Subject: File No. S7-14-08
From: Bill O'Neil

November 4, 2008

Regarding Index Annuities.

Index annuities that have a guaranteed minimal interest rate for the life of the surrender period should not be classified as a security. If your principal is guaranteed how can you classify it has an investment?

With the disclosure forms that reputable companies have that clients must sign when they purchase an index annuity they have adequate disclosure about what they are purchasing. In fact it is much easier for clients to understand than the prospectus that variable annuity and mutual funds have.

Thanks You