Subject: File No. S7-14-08
From: Jon M Gulley
Affiliation: Professional Services Representative

July 14, 2008

It is long overdue that Indexed Annuities be brought under SEC jurisdiction and require Securities Licenses to sell them. While many are good products and have some fixed components, they are sold as gaining the returns of the stock market. My concern is they are not sold as fixed products implying the teaser rate is credited each year over the life of the contract, when it is likely amortized.

Regular variable annuities can also have fixed guarantees, but there is little question they are mutual funds with insurance guarantees. Most can only access the guarantees if the contract is annuitized, otherwise one takes the market value of the underlying securities.

Customers are all to quick to think they are getting a free lunch. Regardless of the regulatory body, it should encourage conveying realistic expectations. The SEC has the advantage of consistent regulation across State lines.