Subject: File No. S7-14-08
From: Thomas A Baker, Jr.
Affiliation: Securities licensed insurance agent

August 25, 2008

To Whom it may concern,

I believe Equity Indexed products should become securities because I have been to two training sessions @ Aviva and Allianz and found that the home office personnel in both Marketing and Management could not explain how the money in the Equity Indexed annuities was credited. I have been at both home offices in June and July of 2008.

At Allianz in July of 2008 I met with the marketing unit and the way they presented their new equity index strategies was with 4 options - the SP, International, Nasdaq and Income strategies. What was interesting was they never disclosed how the clients money was invested or credited yet made it a point to push the 4 indexes they have in the product.

Then their CEO came out to tell us that the Equity Index Products aren't securities yet that is how their people present it. When I asked the Marketing people to explain to me as a client how my money is credited in the account they deferred me to their actuary. If the mrketing people can't explain it at the home offices then why would the SEC believe that people selling them know how to explain crediting.

Sincerely,

Thomas A Baker Jr.
Agent
13523 Forest Lake Dr
Sterling Heights, MI 48312
586-872-7252