Subject: File No. S7-14-08
From: Gerald F Clark, SN
Affiliation: MDRT

July 16, 2008

I do not believe the SEC should become involved with

Insurance and Annuity products. These contacts offer

the Consumer important protection and Guarantees. Premiums

paid, interest credited and reserves greater than most

investments and thrift organizations. I have been writing

Tax Deferred Annuities since 1971 and have many thousands of

dollars on the books that go back to 1978. There is little

difference between the Fixed Annuity and the Fixed Index

Annuity. Only difference, now Bankers, Brokers, CPAs and

Attorneys are writing them. We will just see Extra Charges

and Taxes.