Subject: File No. S7-14-08
From: Jake Fischer, CFA

August 8, 2008

I am in favor of this rule. Indexed annuities are edas securities. They are also sold in a way that brings great compensation to agents as the expense of the elderly.

I see that many agents argued that the SEC should pay more attention to the abuse caused by hedge funds and investment banks. This entertains me.

Hedge funds may exploit the rich and investment banks exploit corporate America, however, FIAs exploit the elderly. Who is in more need of protections?

EIAs are securities as they are subject to investment performance, and should be regulated as such.