Subject: File No. S7-14-08
From: Britton R Riley
Affiliation: Vice President Agency Development Corp.

July 18, 2008

The idea that all Fixed Indexed Annuities are created equal - and are equally bad for the consumer - is ludicrous and shows a disappointing lack of research into current product offerings. There are dozens of Fixed Indexed products available with surrender periods from 4 to 10 years that have contract provisions which mirror or are superior to the contract provisions of the traditional fixed annuities that have been sold for decades. (ie - full account value at death, free withdrawal features, underlying annuitization guarantees, waiver of penalty for confinement and or terminal illness - some even offer a guaranteed Return of Premium now).

In looking at the scope of Variable Annuity sales, combined with the incredibly confusing and costly riders available- shouldn't you be focused on correcting the larger number of consumer complaints about Variable Annuities and inappropriate sales practices before attempting to regulate a product line which, by your own posted observations, you have a limited and out-dated understanding of.

Clean up your own house first before you criticize your neighbor's lawn.