Subject: File No. S7-14-08
From: Harold G Rodgers
Affiliation: Registered Representative

June 26, 2008

Fixed Indexed Annuities (FIA) should NOT be considered a registered investment product. Individuals purchase FIA annuities to safeguard their principal and lower their investment risks. Most retirees can not afford any risk (market or credit) to their retirement savings.

FIA offers the best guarantees that retirees want and need for lifetime income. Because of these strong guarantees, it should not be considered an investment product. Every "registered security" has a good chance of losing value during most holding periods and could go to zero. A risk that investors are never exposed to with any FIA.

FIA's are different. They should be considered insurance products and NOT registered securities.