Subject: File No. S7-14-08
From: Helen M McCourt,
Affiliation: Invester

August 9, 2008

Annunities definitely have their place to provide diversification for one's portfolio. Inurance Agents have to investigate their client's finances in order to make sure they have the proper amount of life insurance. Some people are not sophisticated enough to deal with a Stock Broker and never will, thus it gives the client an avenue to make a safe investment while not consulting with Broker. Many of these clients are good savers, but are losing to inflation by not getting a better interest rate on their money. Therefore, I believe that it is imperative to protect the average client by continuing to allow Insurance Agents to carry Fixed Annuities in their lines.

Helen McCourt