Subject: File No. S7-14-08
From: gary stuart
Affiliation: Certified Financial Planner

July 28, 2008

Indexed annuities should absolutely be considered securities. They are a security product with an "insurance wrapper" and are no different in most cases than a variable annuity, except the sub accounts are an index and not an actual mutual fund. The people selling these products are uninformed and misrepresent them in many cases.