Subject: File No. S7-14-08
From: Roger D Fuhrman

November 29, 2008

I am a licensed health and life insurance agent. I am also a customer of several companies offering indexed annuities and indexed life insurance. These products have provided safety and protection for my family and my clients.
All of the indexed annuity products that I am aware of offer a minimum guaranteed return to policyholders. That is why they are insurance products. The annuity products that I am aware of offer a variety of interest index choices, like a fixed income, bond index, and stock indexes.
These indexed insurance products are not stocks or mutual funds or futures contracts. I don't understand why anyone would think they would be. Policyholders in indexed annuities have obviously protected themselves against potential losses. That is what insurance does.