Subject: File No. S7-14-08
From: Glen E Richter
Affiliation: Financial Consultant

July 29, 2008

Folks,

Were writing you in regards to index annuities. We do not
beleive the SEC needs to oversee them. The reason is the
underline guarantees. Principal is guaranted by the insurance companies plus guaranting at approsimately
2% regardless of how the index preforms. No there not high potential returns like variable annuiites but for the right clients that wants guarantes yet the potential of
receiving higher rates of intrest than fixed annuities there's a fit. It's again our thoughts the oversight of
the state insurance departments over the insurance companies is sufficent.

Thanks
Glen