Subject: File No. S7-14-08
From: Lori S Bennett

July 17, 2008

Indexed annuities are clearly Insurance products and not securities because indexed annuities provide underlying interest guarantees required by state law. Consumers cannot lose their principal in an indexed annuity - they are risk-adverse savings vehicles.

INDEXED ANNUITIES OFFER CONSUMERS IMPORTANT PROTECTIONS, NAMELY: (1) THE GUARANTEE OF PREMIUMS PAID:AND (2) GUARANTEE OF INTEREST PAID.

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

The sales practices and suitability safeguards needed for index annuities are the same safeguards needed for all life and annuity products.

The result of the SEC's proposed rule will hurt not help savers by reducing the availability of agents and products that offer the guarantees they are looking for.

This proposed rule will do much damage by adding unneeded additional expenses (for filing, regulation, and supervision), the cost which will be borne by savers.

The result of this proposed rule will hurt savers by: