Subject: File No. S7-14-08
From: Franklyn R. Deininger, CFP-R
Affiliation: Financial Planning Assn, National Socitey of Pulic Accountants, IARFC, NATP

November 14, 2008

"Comments attached" Indexed annuities are not securities as they use Fixed Rates, Indexing methods, compared to NASD, Dow Jones, SP500 to give a interest credit for that paticular period. The crediting method is interest only. This products are desiged to be compared with fixed annuities, Certificate of deposits with a contract period that could exceed those interest rates.