Subject: File No. S7-14-08
From: Larry K Wilkerson
Affiliation: Registered Representative

August 26, 2008

I whole-heartedly support the SEC's position to declare indexed annuities as securities. As a RR who deals primarily with seniors, the problems I see usually involve a tremendous lack of clarity or disclosure by Index Annuity agents. One local agent even recently ran an ad in the paper saying " stock market returns with no risk" These products are also constantly called Equity Indexed Annuities. It is somewhat humerous to me how now that this issue is being brought forth, the EIA industry now refers to them as Fixed Indexed Annuities. Certainly, I have sold Indexed Annuities in the past. I think they can be very suitable porducts in someone's financial plan. However, they definately need to be registered as security products and more closely regulated.

Faithfully,

Larry (Kirk) Wilkerson