Subject: File No. S7-14-08
From: warren L Hahn
Affiliation: Insurance Agent

August 4, 2008

Index annuity products are in fact an insurance product because the chassis for the product is no different than a fixed interest annuity. The only difference is the insurance company is not declaring the current interest rate as an interest percentage rate, but a cap rate or participation rate on a particular index (SP 500, etc.). The annuity premiums are not invested in the stock index, and the principal and minimum interest rate is guaranteed (unlike a variable annuity where sub-accounts are directly invested and exposed to market risk).

In view of the above index annuities must continue to come under the regulatory authority of the state insurance commissioners, and marketed as insurance products. The insurance commissioners are doing an excellent job in requiring customer suitability questionnaires and full disclosure information at the point of sale (the public is protected and is in noway at risk).

I am available to answer any questions and have 7 year experience in selling index products and 28 years selling insurance products. Warren L. Hahn