Subject: File No. S7-14-08
From: Zach J Engraff
Affiliation: Registered Investment Advisor

August 25, 2008

I believe that Fixed Index Annuities should indeed be considered securities. They are a very complicated product that is often misrepresented to the client in part because they are not understood by the advisors who are selling them. Requiring that the producer be a registered representative can only help to serve the community by ensuring that their representative has at least a base level of understanding of how securities work.