Subject: File No. S7-14-08
From: Robert E Patterson, RHU

July 15, 2008

How can you take exception to a product that guarantees one's principal investment from loss, offers a guaranteed return on investment in a worse case scenario, while offering a potential return equal to market gains in a best case scenario. All of this without loads or fees Yes, one gives up access to their original investment subject to surrender charges for a period of time, depending on the type of product chosen, but then there is a cost for anything. Simply stated, nothing is free. For an unsophisticated investor, Fixed Indexed Annuities can offer guarantees that no market investment can provide against market downturns, and if desired, provide an income that one cannot outlive