Subject: File No. S7-14-08
From: Yoko Sera

July 21, 2008

Fixed Indexed Annuity cannot be treated as Securities. They are not mutual funds, neither variable annuities, even not brokeage accounts. FIA is identical as Fixed Annuity that is NOT directly impacted by market fluctuations. Negative investment risk is ELIMINATED. FIA is governed by Each State for its suitability and sales practice. The Complaints goes to State immediately and resolve locally with less cost. And purchasing FIA is no cost involved. However, if securities, there are remarkable high separate account manager fees charged and it affects the value of the investment. I am a security licensed and I strongly believe FIA or Equity Indexed are not security products. The FIA is the fixed annuity without the high risk of market fluctuations and the low risk investment with no cost.