Subject: File No. S7-14-08
From: Daniel J Carlberg, PhD
Affiliation: Tax and Financial Services

July 2, 2008

I am sorry, but I do not understand how a client can be protected by receipt of a "Prospectus" designed to outline risks. Individual contract owners are not investing in under laying securities. Insurance companies are at risk and not policy owners. With the stock market dropping almost 20%, I am not aware of one index annuity owner losing value. The only risk of loss is not associated with the underlaying investment, but with a specific fixed contractual surrender charge. Granted earnings may be limited, but in todays environment that is not bad considering guaranteed protection from loss.
This is a bad idea, and another example of protecting people from perceived sales abuses and not product abuses.
Each state is well equipped at controlling and punishing unscrupulous marketing agents.
Thank you for listening.
Daniel J. Carlberg