Subject: File No. S7-14-08
From: Jane Washburn, MBA
Affiliation: Financial Advisor and Wealth Management Specialist

September 9, 2008

Agents for index annuity products should be held to the same licensing standards as registered representatives. These are products that are tied to securities and should be treated as such. I have had numerous clients who have had disasterous experiences with these products, dealing with agents who have no concerns for suitability or the prudent investor rule.