Subject: File No. S7-14-08
From: James W Protho , Jr
Affiliation: General Agent

November 17, 2008

I think this rule should not pass. Index annuities are not security products since the y are not stock options. They are an insurance product and should remain that way. Why is the IRS so concerned about the index annuities and why all the changes now that they have dropped the ball on securities?