Subject: File No. S7-14-08
From: Jack A Douglas
Affiliation: Registered Representative

July 10, 2008

I fully support making Indexed Annuities a product that requires Series Six registered representative status to sell them.

It is my belief that this product is presented by many as a fixed annuity, but how can it be fixed if any year that the market does not make money, there is no gain on the basis amount. A true fixed annuity earns money every year no matter what the market does.

Any product that is tied to the market and can result in no gain in any certain year period, should not be called a fixed annuity, but should require full training and SEC/NASD registration to be able to sell it.

Personally, I have found these products to be sold to seniors that do not realize the extra long surrender periods, and the high rate of penalty for taking money out early. This borders on fraud.

Jack Douglas
Registered Representative