Subject: File No. S7-14-08
From: Paul M Breithaupt
Affiliation: Registered Representative, Investment Advisor

July 30, 2008

Indexed annuities should not be treated like variable annuities. They have guarantees. They can't lose money. Change the way they are advertised or the selling disclosures, but putting them under FINRA is basically just a power grab and a grab for commission revenue by broker-dealers who give us a haircut on our commissions and keep the money for themselves.