Subject: File No. S7-14-08
From: Marcus Solorio

September 6, 2008

Both the design and sale of annuities are highly regulated by state insurance departments as are the companies who manufacture and sell them. State insurance regulations cover, among other things, suitability of insurance agent recommendations regarding annuities, annuity disclosure and advertising, agent licensing and training, unfair trade practices including misrepresentation of product terms and conditions, and enforamnt actions and penalties for noncompliance with sales practices requirements. In addition, guaranteed minimum vales for annuities are regulated thorough the Standard Nonforfeiture Law and are applicable to all fixed annuities.