Subject: File No. S7-14-08
From: GayLee Ellis
Affiliation: Register Representative

November 17, 2008

My clients that have purchased Index Annuities and have all done so because they are not securities and subject to rick of loss from market activity. Many of those are IRA types of investments.

Fixed Index Annuities are subject to comprehensive state Insurance regulations. The insurance company is responsible for their investment but my client is not at risk. If you send this type of sale through a brokerage house there will be a lot less sales through the agent force for various reasons. One is that not all insurance agents are licensed to sell securities. Second, the brokerage firm takes a serious profit from the selling agents commission for no reason. This is not a security to the client so therefore should not be required to be regulated as a security.