Subject: File No. S7-14-08
From: Corey J Birdwell

October 17, 2008

SEC,

I have been selling indexed annuities since 1996. I always could sleep at night knowing my clients would not loose money in those lean years. I was licenced with Raymond james financial services for 15 years. They were the first to act on the mere suggestion that indexed annuities are a security. We moved everyone to variable annuities that have high ME costs with riders for GMIB. ( RJ did lead industry in lowering VA expenses ). Still today Indexed annuities are an Insurance product not a security. Corey Birdwell