Subject: File No. S7-14-08
From: Daniel R Wilson
Affiliation: Registered Investment Advisor Agent

July 17, 2008

Regardless of the fact that the Indexed annuity provides a fixed rate of growth it is tied to a security based index it is the understanding and continued process of staying abreast of the security market that effects this index that is of primary concern. If you are not required to keep up a license and therefore an education process on securities, the ability to provide the client the best possible explanation of this product and its ramifications with respect to the securities values and thus the value of the indexed annuity is compromised. Therefore I feel that this product should be classified as a security.