Subject: File No. S7-14-08
From: Phillip M Younts
Affiliation: BSBA

August 29, 2008

I've been in the Insurance business since 1981 and understand while working with clients there should be
regulation and rules to follow. There should be suitability, accountabilty and ethical behavior involved as well.But I don't understand how a fixed insurance product can be considered a Security. Please allow the fixed index annuity to remain in the status as it always has been, an insurance product. Thank You.