Subject: File No. S7-14-08
From: Robert M Draughon, Jr.
Affiliation: CLU, ChFC, AEP

July 11, 2008

I have been in the financial services business for over 36 years, and I dont think I have ever seen an indexed annuity that worked as the client thought it would. They are being sold as an equity investment with no risk. This is not a fair representation to the public and it should be regulated just as variable annuities are.
Investments are investments and the public should expect the sales people they deal with to be educated and ethical, the only way to insure that is to regulate the product. My old manager once told me you never get what you expect you get what you inspect.