Subject: File No. S7-14-08
From: GARY J RAGGIO

September 4, 2008

I HAVE MADE MORE THAN A FEW COMMENTS IN THE LAST SEVERAL WEEKS REGARDING THE ASSERTION THAT AN INDEXED ANNUITY SHOULD REMAIN A FIXED ANNUITY, MOSTLY BECAUSE IT PASSES ALL OF THE TESTS FOR BEING A FIXED PRODUCT.
I HAVE TWO OPEN ENDED QUESTIONS THAT I AM SURE WILL NEVER BE ANSWERED. 1. WHAT IS THE DEFINITION OF A SECURITY? 2. WHAT IS THE DEFINITION OF A FIXED ANNUITY?
THERE ARE REGULATORY BODIES THAT GOVERN THE SALE OF FIXED PRODUCTS AS THERE ARE FOR SECURITY PRODUCTS, ALLOW EACH TO PERFORM IN THEIR RESPECTIVE ARENAS,