Subject: File No. S7-14-08
From: Thomas E Reich

August 13, 2008

there are a few major issues here.

1. complexity of the products causes in my opinion a need for more knowledge by the salesperson, so I think for that reason it should be deemed a security.

2. If the advisor can control the % of what indexes the $ goes into (NASDAQ,SP,etc), then they are in a sense giving investment advise even though they can't change what securities are held in the index.

3.the cost to the companies will be high, which as we all know will be transferred to the customer in some form, which is bad for the consumer.

4.Getting more advisors licenced to sell this product may cause them to start giving more investment advise in unrelated areas even if they are not really qualified to do so, again, bad for the consumer.

5.Advisors will lose $ if comp goes thru the grid.

My BD (NFP Securities Inc) already deems Index Annuities to be a security, which I think in the overall scheme of things is the right move. Ultimately the advisor and customer needs to understand the product better. I would advocate that even more than securitization.