Subject: File No. S7-14-08
From: Ralph E Hunt, Dmin

July 17, 2008

Dear Sirs:

I am an independent insurance agent in South Carolina. I serve retirees along the coastal areas and have, and will continue to recommend indexed annuities to my clients.

They products are designed for safety and security of life savings. My clients have been pleased with the returns and recently have thanked me for the feature that does not allow them to lose money in down markets.

I HAVE NEVER, EVER HAD A COMPLAINT.

They know in advance, the how these work. These are not rich people, nor are they greedy. They just want the advantages of market returns without the risk. Plus, the tax deferral is to their benefit.

Some have moved their funds from losing funds to me. Why? Not because I recommended or SOLD them on it, rather because these "fit" their objectives.

These are insurance products. Not securities.

Thank you,

Dr. Ralph E. Hunt
Mt. Pleasant, SC