Subject: File No. S7-14-08
From: Frank Bruzzese

August 25, 2008

a "FIXED INDEX ANNUITY" HAS GUARANTEES THAT A TRUE "SECURITY" DOES NOT HAVE. THE ANNUITANT'S MONEY IS NOT IN THE MARKET AT ALL, IT IS IN THE SAME SAFE VEHICLES USED FOR "LIFE iNSURANCE" WHICH IS NOT A "SECURITY." THE SEC IS LOOKING WOMEWHAT AVARICIOUS.