Subject: File No. S7-14-08
From: Richard J Schillig, CLU, ChFC
Affiliation: Independent insurance agent and financial professional

June 26, 2008

I am life, health and series 6 broker with 30 years of experience in advising clients. We have been using index annuities for past 7-8 years as part of client portfolios to bring some safety and growth potential without risk for retirees. Our marketing activities include compliance approval by both fixed and securities compliance departments. Based on this experience, my observation is most broker dealers do not understand annuities especially index annuities. The regulations of the fixed compliance areas of insurance companies have been much more strict than the securities side. Including fixed index annuities under the securities side just doesn't make sense.