Subject: File No. S7-14-08
From: Jim Charbonneau

November 13, 2008

To whom it may concern,

Index annuities are a nightmare of imaginary benefits, tremendously high costs and, in this day of the guaranteed variable annuity, have no place as an investment. In the past I have been invited to classes on how to attack the elderly and make myself rich selling these rotten products. I have never sold one and our firm backs us with no selling of theses products. Whatever can be done to stop, eliminate or do away with these is a benefit to all mankind.

Jim Charbonneau
FPA 10+ years
17 years lic. With Series-7, 63, 65, and 24