Subject: File No. S7-14-08
From: Lawrence E Marcus
Affiliation: CEO Marcus Edwards Inc.

July 12, 2008

During the recent bear market our clients have had no concerns or any stress concerning there index annuities because of the traditional guarantees offered through a fixed annuity. The risk associated with securities investments in know way correlate to the lack of principal risk associated with index annuities. The only one who will benifit from index annuites being registered as a security will be broker dealers who will reguire the independent agencies to be registered representatives and would then require payments from us of 10% to 30% gross sales , just to continue to sell a principal risk free annuity that is already regulated by the state. The hardship to my agency to comply with the added cost and lower margins will definetly create a hardship for myself and my employess.