Subject: File No. S7-14-08
From: Dennis G Williamson
Affiliation: Certified Senior Advisor

August 25, 2008

I, AS AN INSURANCE AGENT, BELIEVE ALL "EQUITY INDEXED AND FIXED INDEX ANNUITIES" SHOULD ONLY BE MARKETED THRU SECURITIES LICENSED ADVISORS.

THE VAST MAJORITY ARE MARKETED AND SOLD BY INSURANCE AGENTS AS IF THEY WERE "INVESTMENTS".

INSURANCE AGENTS REGULARLY ADVISE PROSPECTS/CLIENTS TO MOVE FROM STOCKS, BONDS, AND M/FUNDS POSITIONS IN THE NAME OF "SAFETY". THIS "ADVISE" IS INVESTMENT IN NATURE AND NOT INSURANCE.

NO INSURANCE AGENT WITHOUT SECURITIES LICENSING SHOULD EVER BE ALLOWED TO ADVISE A PROSPECT OR CLIENT TO SELL A SECURITY TO BUY AN ANNUITY. PERIOD......