Subject: File No. S7-14-08
From: James G Doyle
Affiliation: VP, CLient Relations, Inspire Financial Group

July 12, 2008

I do not believe the sale of Indexed Annuties requires SEC oversite for the following reasons:

A) Indexed annuities are risk - adverse savings vehicles - they are not high-risk investment products where a consumer can lose his or her principal

B) Indexed annuities offer consumers important protections, namely: (1) the guarantee of premiums paid and (2) guarantee of interest credited

C) Indexed annuities provide underlying interest guarantees required by state law

D) 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.