Subject: indexed annuity

August 27, 2008

I oppose rule 151A as it applies to indexed annuities. Indexed annuities are fixed insurance annuities and have not direct relationship with equity investments. The crediting of interest to these products is based on what the equity market may do but not based on equity within the annuity product. There is no risk of loss of principle like a mutual fund or a variable annuity.

Van Biggs