Subject: File No. S7-14-08
From: Dwight S Barrett

November 17, 2008

I am strongly against the reclassification of Indexed Annuities to securities. Look at the people with Indexed Annuities and the ones invested in the market and you will see that nobody lost any money due to the fact that the Principal is completely protected. The people aren't buying an investment they are buying an insurance contract with guarantees on their principal. I sell investments so the change won't affect me in having to take the tests to be able to sell securities. It's because I sell securities that I can tell the difference between them.

I don't understand how anyone can look at Indexed Annuities and classify them as securities.

I hope you will leave the Indexed Annuities alone as they are not securities