Subject: S7-14-08

July 24, 2008

I am not sure I understand where this is headed? My feeling is that indexed annuities should be treated as a security such as variable annuities and representative selling these annuities should have a series 6, 63 and a Life license. If you have to use the words stocks, stock market, or indexes in your explanation of a product it should be considered a security.

Richard J. Carlesco Jr. LUTCF
IBN Financial Services, Inc.