Subject: File No. S7-14-08
From: Roy L Panelli
Affiliation: CFP

August 25, 2008

Equity indexed annuities are not understood or suitable for the majority of people who are talked into buying them. The sales practices used to market them is completely unacceptable. The insurance industry is not going to object to these products being a security because once they are defined as a security the guarantee now in place will be removed and the liability will shift to the buyer.