Subject: File No. S7-14-08
From: william e rice
Affiliation: CEO Michigan Securities

July 16, 2008

I would like to see all annuities treated as securities, including straight fixed annuities. These are being sold as investments and it doesn't matter if the rate of return is based on an index or as in the case of fixed annuites based on a bond portfolio. The fact that returns on fixed have a "market adjusted value" clause confirms this view. Experience tells me the people who sell annuities and don't have a securities license aren't as knowledgeable as those who do. Might as well jump in with both feet rather than fight the fixed battle later on.