Subject: File No. S7-14-08
From: Rhonda K Fisher
Affiliation: IAR

November 17, 2008

I believe that indexed annuities are not securities and not be treated as such. They fixed products offered by insurance companies that guarantee your principal and you can not loose money because of the market declining as you can actually in the market. This is a great product for clients that are willing to give up some up side gain to protect their principal from lose.