Subject: File No. S7-14-08
From: Wally D Broussard
Affiliation: Chartered Financial Consultant

July 15, 2008


Since 1971 I have helped my clients in Louisiana and Texas retire in comfort using Fixed Annuities.

The SEC's attempt to regulate Fixed Indexed Annuities is outrageous because the Fixed Indexed Annuity satisfies the "Safe Harbor" rules set forth by Federal Courts.

These annuities involve NO RISK to Principal if held to maturity. They are NOT investments.

They cause very few consumer complaints when compared to Variable Annuities which are investments and are currently regulated by the SEC.

I do NOT think that any Fixed Annuity should be regulated as an investment.

Wally Broussard, ChFC, CLU