Subject: File No. S7-14-08
From: Lis Libengood

November 24, 2008

I'm 54 years old. I OWN an Equity Index Annuity. I invested $10,000 I did NOT want to risk losing into it. I got a bonus of $1000 for doing so. In the first year, with the market UP, I made $1817.59. I had a total of $12,817.59.

In the second year, with the market being more down than up, my balance was STILL $12,817.59.

And now, in this third year with the market being down some 50% in many cases, what is my account balance? It is STILL $12,817.59.

The EIA performed EXACTLY as it was intended to do. I opened the account wanting NO RISK and potential upside, and that's EXACTLY what I got.

In my experience, NOT being exposed to market downside risk means that my EIA is NOT a security. Please, sirs, find me someone with a Variable annuity or any other security whose balance is not down in 2008.

EIA balances are NOT down in 2008 and EIAs are NOT securities.