Subject: File No. S7-14-08
From: Joyce A Gibbs
Affiliation: Licensed Insurance Agent

October 28, 2008

I wish to make my position known to stop Rule 151a.

Simply-stated, Equity Index Annuities are fixed annuities due to the fact that they are designed with a "no risk" factor to the Clients' principal or earned interest - unlike Securities. Therefore, due to this major fact, I hold firm that indexed annuities should remain a product available to Life Agents.

Thank you.