Subject: File No. S7-14-08
From: RONALD G MARTIN

November 18, 2008

By their very definition, securities have a market risk component. By their very definition, fixed annuities do not have a market risk component. Why then should fixed indexed annuities be wrongly reclassified as securities?
The answer, of course, is that fixed indexed annuities should not be reclassified as securities.