Subject: File No. S7-14-08
From: Marta Nystrom

August 25, 2008

My business primarily revolves around direct portfolio management for clients. I occasionally use indexed annuities for clients who are very risk intolerant because, while they limit upside potential, they insulate the client from market loss.

Simply by virtue of the fact that they insulate the client from market loss, it seems impossible to classify them as investments. They are not. They are NOT like variable annuities and should not be treated as such by the SEC.

There is already so much over-regulation of the industry that is not helpful, it boggles the mind that even more is being considered at this point.

I know brokerage firms would love to control this arena, but please don't go there. It's not appropriate.

Thank you,
Marta Nystrom