Subject: File No. 4-606
From: milt v bauguess, clu,chfc
Affiliation: mdrt,naifa(local,state,national)

August 7, 2010

comments: IN the current economy index annuities could truly be the savior for many retires who want to insure they get a decent return on their retirement funds, an alternative long term care benefit, a 4% return as a death benefit, and finally a return based on the standard @ poor 500 with no market risk and no cap. To have these benifits regulated by a broker dealer makes absolutely no sense. You are only adding another layer of bureaucy which has proven time and time again they cannot be self regulated. If you need more info please call me at 850-656-3400.