Subject: File No. S7-14-08
From: Gary Robertson
Affiliation: LUTCF

July 31, 2008

I have been offering clients indexed annuities since they first became available. They are certainly not a securities product (I should know since I have also been a securities rep). Index annuities offer insurance guarantees which you cannot find in market related products. Index products are simple to understand and guaranteed safe. Please do not put them in the same arena as securities products.