Subject: File No. S7-14-08
From: Robert W Price

July 8, 2008

-I have worked in this industry for more than twenty years and know that the insurance commissioners in my state have done a great job in policing insurance agents that sell fixed index annuities. The consumer does not own shares in any security, nor does their account value fluctuate due to market volatility. The consumers funds are not held in a separate account. Instead premium are place into the general account of the insurance carrier. It is grossly inaccurate and borderline reckless to state that a purchaser of an index annuity may suffer investment risk. Insurance companies have successfully developed and designed innovative solutions promoting this benefit, which appeals to purchasers on the familiar insurance mainstay of stability and security. The fact is that within a Fixed Indexed Annuity the majority of the investment risk for theequity-linkedfluctuation is NOT borne by the purchaser. And unlike true security products, the purchaser is NOT directly impacted by market fluctuations. Negative investment risk fluctuation to the purchaser is eliminated entirely. Keep the SEC out of fixed products supplied by insurance companys and banks.

Sincerely

Robert W Price