Subject: File No. S7-14-08
From: Bernard E McCoy
Affiliation: CLU, ChFC, RHU

July 31, 2008

I do not belive that Index annuities should be classified as annuities. They come with a Guarantee of Principal. If there is no risk to principal it cannot be a security. Any marketing problems should be addressed at the insurance company and agent level.
There is no need to throw the baby out with the bath water.