Subject: File No. S7-14-08
From: Jean Cobb
Affiliation: National Financial Partners

July 21, 2008

Indexed annuities are a safe savings vehicle that offers certain guarantees that would benefit most risk adverse consumers. Its guarantees qualify it as a fixed annuity which have been designed and regulated by the insurance industry for almost 100 years. Reclassification of indexed annuities as an SEC vehicle makes about as much sense as reclassifying a bank certificate of deposit thru the SEC. Annuity product design and evolution has been successfully managed by the insurance industry thru the NAIC model. Reclassification of indexed annuities as a security would displace thousands of insurance professionals and mislead the public into thinking that indexed annuities are securities.