Subject: File No. S7-14-08
From: Robert L Gardner, Jr

July 29, 2008

I understand the reasoning for the SEC to consider the Fixed Indexed Annuity as a security, however, it certainly has all the characteristics of a fixed product. More importantly, no client funds are ever at risk. I find it odd that the SEC pushes so hard in this case when Wall Street Investment Bank CEO's got incredible bonuses in 2007 for duping their sub-prime investors and the SEC plays party to the entire scam. Shame on you