Subject: File No. S7-14-08
From: Terrance A Shepro
Affiliation: Member of N.A.I.F.A.

July 30, 2008

Your decision to place index annuities under the same licensing requirements as variable and securities products is going to hurt many seniors who need these products.

I'm all for strict enforcement of ethical standards for anyone in the insurance business or anyone who deals with seniors. This ruling will not prevent any wrong doing in this market. It will only serve to make those who provide products senior citizens need more difficult.

I would ask that you reconsider this action.