Subject: File No. S7-14-08
From: Scott M Tober

August 4, 2008

As a financial professional for almost twenty years, I have been involved with both the securities side and the annuity/insurance side of the business. I have offered both securities and non securities to my clients, and have seen the merits of utilizing both for my clients.

With the above in mind, it seems inappropriate to classify the fixed index annuity as a security. These annuities offer minimums and guarentees that a security can not. Most
states have some form of "legal reserve" or consumer protection fund.

A registered rep is not required to have an insurance license when offering a security as an alternative to a fixed annuity, and the same standard should be applied to an insurance agent.