Subject: File No. S7-14-08
From: James R Richards, Jr

July 8, 2008

I disagree with the SEC suggestion that Indexed Annuities are considered a security. I have sold insurance products for 34 years and this product does not look like or smell like any security.
I furhter disagree that Indexed Annuities are bad for seniors. There is never a risk to principal and there are guarantees that seniors cannot get with securities. With this in mind, why would a security with no guarantees be better for them than an Indexed Annuity with guarantees?
I have always agreed with insurance companies that indexed annuities are a type of fixed annuities and does not fall under the regulations of the SEC.