Subject: File No. S7-14-08
From: James Pruitt, Ph.D.
Affiliation: None

July 18, 2008

a fixed annuity of any kind is not a security ...

it's the interest rate that varies no matter how it's calculated ...

according to your logic you would include participating life or annuities and universal life as a security ...

we've already been down that road with the SEC before ...

life insurance products life or annuity are not securites and just your saying so does not make them so ...

Life insurance and annuities have a guarantee of 100% principal and protections ... something that no security has or ever will have ...

I think you guys would just like to get in control of the insurance business that the courts have said that you have no business in ...