Subject: File No. S7-14-08
From: Eric D Brady
Affiliation: Financial consultant

November 5, 2008

As a financial consultant I feel you are on the right track in regulating indexed annuities as a securities product. People are being told that they get to participate in the market's returns with no downside risk. They believe that they are investing in the market I have had many situations where the people were not told about the basic functions and costs associated with these contracts. All they know is they get to participate in all the market returns in the up years and no loss in the down years. They are not told about the costs, caps or participation rates. It is amazing to me how little people know about what they just purchased. What is even more amazing is that the agents selling these contracts do not understand the details of how they work Indexed annuities are designed to pull senior's money without doing any type of planning for the individuals as to what is really best for their situation. This product is marketed as a security and should be regulated as a security. I have access to indexed annuities but have found very few situations that they benefit the individual.