Subject: File No. S7-14-08
From: Keith Buchanan

August 7, 2008

The product needs to be an insurance product only. If the Insuance company want to make the indexed annuity with a prosepctus then it would fall under as a variable annuity. The Hartford has a fixed product that has a preset interest rate for 5 7 and 10 years and it is sold with a prospectus so it is a fixed product but sold with a prospectus. However it has fixed product that aren't sold with a prospectus and they can be sold with just an insurance license. The insurance company should be able to choose the channel they wanto to put out the product line. The indexed annuity has in its product a fixed interest rate so the client knows what the botton line is. However if the index performs better it gives a better return.. Variable annuities has no support if the market goes down so does the value. That is the biggest difference and is the reason it should be only sold in the insurance channel.

Thanks