Subject: File No. S7-14-08
From: James C Hughes, Jr

November 17, 2008

I am a former Series 7, Series 24 Licensed Broker. I have from time to time sold fixed index annuities.

My opinion is that they in no way represent a "seurity" under my understanding of the rules that govern the SEC, NYSE, or NASDAQ. In my years as a stock broker and broker manager...I never heard of a product that offered a guarantee of anything.
Fixed index annuities do just that. They provide a guaranteed floor with a required reserve agreement that is far better than the FDIC requires of banks. Yes the performance of the product is subject to market changes...but, my clients have felt more secure with these investments (with professional management) than any relationship they have experience with brokerage houses. These investments should NOT be regarded as "securities" given that they offer guarantees. Please do not remove this investment opportunity from the investing public

Sincerely,

Jim Hughes