Subject: File No. S7-14-08
From: John E. Lovelace, Sr.

July 17, 2008

The SEC should not be considering the Indxed Annuity as any thing except what it is, because it has all of the characteristics of a regular annuity. There is not risk to the annuitant. His value will never be less that his initial premium, unless he elects to make withdrawals.