Subject: File No. S7-14-08
From: George Richards

July 12, 2008

i have sold fixed-indexed annuities for a while and i will say abuse and misunderstanding are a common theme. unfortunately for those not securities licensed, the agent(s) involved need significant training to understand the implications of what is being sold as do the consumer(s).

i would recommend making this a security or something where a basic life/health agent cannot just pick it up and sell without significant investment in training, certification, etc.

thank you for working towards making the consumer environment safer.