Subject: File No. S7-14-08
From: Charles H Ling

July 16, 2008

1) Indexed Annuities offer consumers important protections, namely (1) the guarantee of premiums paid and (2) guarantee of interest credited

2) Indexed Annuities provide underlying interest guarantees required by state law

3) There is little difference in the risk to a consumer for a traditional fixed annuity versus an indexed annuity. Under both forms of annuities, the policyholder is at risk to the insurer's annual interest rate declaration, whether it is an expressed percentage amount or a formula relating to changes in an index.

4) The proper supervision needed for traditional fixed annuities, fixed indexed annuities and life insurance is being performed according to state insurance department rules

5)Further regulation in addition to the State is not called for.