November 22, 2008

Subject: File No. S7-14-08

Dear Commission,

In reference to indexed annuities and derivatives it is my opinion that they should be regulated as securities and only insurance agents who are security licensed should be allowed to sell them. This is based on having taken the insurance license course and feeling that an understanding of the market indexes is not addressed in the insurance exam.

C. Carter Boucher, CFP®, CRPC®
BOUCHERCapitalManagement, Inc.