Subject: File No. S7-14-08
From: Dan P McBrayer, CLU

July 30, 2008

Indexed Annunities should remain OUTSIDE of the register rep area. These plans do not require someone to be a stock broker or mutual funds sales person in order to be able to fully explain these plans. Insurance companies have done a good job of creating brochures and forms that explain how these plans work.

When a registered rep sells stocks and mutual funds and VA's there is a risk of the client losing money...that is why someone needs to be licensed with the NASD to be able to sell these products. Indexed Annunities allow the person to never lose their original investment. I just think there too many other areas for you all to police rather than adding the sale of Indexed products to the list.
Thanks