Subject: File No. S7-14-08
From: Ken J. Gallagher

August 25, 2008

IN OPPOSITION to proposal to classify Index Annuities as securities.
1. IAs are subject to no market losses.
2, Most guarantee a minimum return.
3. Suitability regulations are already in place, and
monitored by the State Insurance Depts Insur. Cos.
4. Retirees are looking for SEUCITY GROWTH. Mutual
Funds offer them NO safety.
5. retirees are intelligent enough to know that if they
follow the rules regarding total surrender, they
will not lose. They already understand that in CDs
They can withdraw 10%-20% annually. And, they are
accessible for medical emergencies. The rules
already are very clear, and in print.
6. If clients take full early withdrawal,they
will likely lose no more than they are presently
losing in the market.