Subject: File No. S7-14-08
From: deborah alpert
Affiliation: Ins. Agent and purchaser myself

July 19, 2008

I offer these Ind. Ann to many employees of schools. This is asked or me to give them security on they dollors, no risk. Most of these people do not have or have educated them selves to keep up with Markets. They want to keep their lives simple...don't play the market, don't want to loose what they put in.
To now offer this thru Brokerage houses and treated like securities, is only going to stop Selling these products, cause there is no investment pass on to the holder . There will be additional charge thru Brokerage houses. Does not leave much left after all expenses on this product.
I also been reading in such "National Underwriter Life/Health Mag" that brokerage houses and Mutual funds the variable annuity sales have DROP 12.4% 1st qtr 2008.
When other parts of the industry is loosing sales, don't they look for some way to gain back what is lost...they want a share in the action? Because of the unstable time for MANY in the market...every one is being effective.
If its not broken why redo the WHEEL...THIS PRODUCT WILL THEN NOT BE SOLD AS IT IS NOW...will not be an attractive product....