Subject: File No. S7-14-08
From: Danielle M Penrod
Affiliation: Office Administrator, Accuarate Solutions Group

August 11, 2008

Thank you for making the effort to protect consumers. We all understand that there are, unfortunately, advisors who do not taking into consideration the best interest of their clients. This however is not the case for all advisors. I do not feel the above referenced propsed ruling will necessarily cause the unscrupulous advisors to simply stop selling because the product becomes a security.

An indexed annuity is a very viable solution for many of our clients who are adverse to taking risks. Indexed annuities are so popular because our clients CAN'T lose principal as a result of market downturns. Given the state of our economy over the past 6 months you can understand the sense of safety that a client feels. It is because of the guaranteed principal that an indexed annuity shoud not be a security.

The insurance industries are taking steps to make certain that these annuities are are suitable for clients. This is done both through compliance and suitability acknowledgements. Additionally, our office uses another suitibility analysis form to make certain that we offer a product that is the best fit with our client's needs and goals.

Finally, with our economy in such a state of uncertainty and turmoil, major changes to the daily operations of insurance companies, large marketing organizations and small sole proprietorships like ours, will surely generate additional financial stresses and instability.

In summary, our industry has taken steps to ensure that clients are purchasing products that fit their needs and goals. Allow our industry to complete the process they have already begun.

Indexed annuities are guaranteed products. Clients have not lost money due to market losses. They are a very viable product and this proposed ruling would prevent those individuals who are adverse to risk and who are qualified to keep from hearing about same.

The potential financial impact could be tremendous. Tens to hundreds of thousands of jobs and multiple millions of spendable income could be stripped from the economy. I think that we can all agree that this is the last thing our country needs.