Subject: File No. S7-14-08
From: Warren Cook

July 15, 2008

I am strongly opposed to the proposal to treat equity-indexed annuities as securities, not as insurance.
I feel that the indexed products were developed to give the public an additional option for investing in retirement funds with potential for greater gains that traditional fixed rate annuities, without them having to be involved with high risk security products.
I personally have not had one complaint from any clients who have purchased equity-indexed policies and see no reason for those products to only be represented by individuals licensed to sell securities.
Thank you for asking for comments.