Subject: File No. S7-14-08
From: John G McHugh
Affiliation: Insurance agent and management consultant

July 29, 2008

There should be no need for an insurance agent to have a Series 6 license for the sale of Indexed Annuities. The premium funds in these products are not in the stock market. Only the SP 500 is used by these insurance carriers as a "benchmark" measurement with different types of measuring sticks to generate a potential interest crediting rate higher than the guaranteed rate. Unlike equity-based products (i.e., variable annuities, mututal funds, etc.)the person's principal amount is guaranteed never to be lower than than premium deposits. Plus, their interest received/earned is also guaranteed, once it is earned. These are safe products for a portion of a person's financial holdings, where this level of guarantee is important to them.