Subject: File No. S7-14-08
From: James L Sanford

August 5, 2008

Index Annunities are very good products and not for everyone. I have been in the the financial services industy for over fifteen years. Ten years ago nobody was concerned about the product until people started to understand how the product worked. It is easy to understand and some people like the concept. Fixed annuities have be around a long time and now the Broker Dealers wants to make it a securities prouduct.

Index Annuities are fixed annuities and insurance product many people call them TSA's. Many broker dealers and financial firms want to offer the customers Mutual Funds and Stocks. They say Index Annuities are bad for the client and at the same time want to make it a securities product and not offer it to the pubic only if they are asked and many people today still don't know anything about Index Annuities.

I hear people say the terms are too long, however people that plan to invest in Annunity or Mutual Funds the general rule is 5-10 years and sometimes longer. People understand what they want and this is just one product to help clients reach their financial goals.