Subject: File No. S7-14-08
From: Judy B Gorton, Ph.D.

November 17, 2008

We are not in favor of requiring a securities license to offer fixed indexed annuities. We feel this deprives our prospects that choose to have a guaranteed no loss annuity which has upside potential with no downside loss, a guaranteed death benefit, and a guaranteed living benefit for their lifetime. Mutual Funds and Variable Annuities do not offer all of the above. Conservative individuals should have a choice.

Suitability and regulation by the states is already in place. Requiring a securities license would eliminate a huge number of current agents who would prefer to work with fixed index annuities.