Subject: File No. S7-14-08
From: Allan M Harris

July 30, 2008

Fixed Indexed Annuities are not securities and should be left alone by the SEC. FIAs provide the client with Guarantees that are not available with Securities and look more like an Insurance Product than a Securities Product.

That is why there are Variable Annuities. They accommodate
the SEC requirement for Securities.

In addition to the above, FIAs earn interest and have no share price. While they participate in earnings based on
the change in the indexes from year to year, they have no share price and have no footprint relating to a security.
They look more like a CD than a security.

Allan M. Harris
55 Years of Insuranace Service