Subject: File No. S7-14-08
From: Raymond Huff
Affiliation: naifa

November 18, 2008

in our firm we have 50 to 60 million of our clients dollars that are being held in fixed indexed annuities. we are and our clients are very happy that they have not lost any of their funds in the recent months due to the meltdown of the market. as said no one has lost money due to wall street loses. since these funds (indexed accounts) have not caused a loss, how can they be considered to be a security? i and our clients would be very unhappy and put at a disadvantage if the rules and regulations on the fixed indexed annuities are changed. Raymond Huff lutcf