Subject: File No. S7-14-08
From: William B. Demaree

July 30, 2008

I beleive indexed annuities should be kept as an insurance product for the following reasons:
1. It's a guaranteed product unlike securities.
2. The index options are a choice to consumers. They still can select a fixed rate of return each year in their contract.
3. The Insurance Industry has done an excellent job of new and better suitabilty and disclosure forms so consumers better understand these products. (Does every consumer understand a prospectus?
4. Can a security product say safety of principal like an fixed insurance product?