Subject: File No. S7-14-08
From: Christopher Thomas

October 13, 2008

Fixed indexed annuity premiums are deposited into a "General Account" not a separate account like Variable annuities which are registered as securities because of the possibility of market losses due to the underlying investments in securities that can lose value due to market declines. A Fixed indexed annuity policy holder CANNOT lose money due to market declines. The only way a fixed indexed annuity policy holder can lose money is if he/she were to surrender the policy just like ANY OTHER FIXED ANNUITY. For these reasons, fixed indexed annuities should remain regulated by the State insurance departments ONLY, just like every other form of FIXED ANNUITY.

C. Thomas