Subject: File No. S7-14-08
From: Andrea Hoxie

July 12, 2008

I strongly oppose the recharacterization of equity indexed annuities as securities.

There is little difference in the risk to a policyholder for a traditional fixed annuity versus an indexed annuity. Under both forms of annuities, the policyholder is at risk to the insurer's annual interest rate declaration, whether it is an expressed percentage amount or a formula relating to changes in an index. The sales practices and suitability safeguards needed for index annuities are the same safeguards needed for all life and annuity products.

The results of the SECs proposed rule will not be to benefit savers but to:

1. Reduce the number of agents who can offer a product that is beneficial to many savers

2. Burden indexed annuities with unneeded additional expenses (for filing, regulation, and supervision), the cost which will be borne by savers

3. Damage financially many individuals, small businesses, and smaller insurance companies and

4 Give Broker/Dealers the ability to suppress a viable, valuable, and successful form of retirement savings which has and would continue to provide strong competition to those retirement savings offerings traditionally made by Broker/Dealers.