Subject: File No. S7-14-08
From: wayne l WEBER, CLU
Affiliation: CLU,CHFC

August 5, 2008

TO DEEM AN INDEX ANNUITY AS A SECURITY MAKES NO SENSE.THERE IS NO DOWNSIDE RISK AS A SECURITY WOULD HAVE. I UNDERSTAND THAT THERE ARE SURRENDER CHARGES, HOWEVER CD'S HAVE SRRENDER CHARGES AND YOU ARE NOT LUMPING THEM INTO A SECURITY BOX. THESE PRODUCTS SHOULD BE MONITORED AND SOLD PROPERLY, AND THE INDUSTRY IS CERTAINLY JUMPING ON THAT. THERE ARE SO MANY OTHER MORE URGENT THINGS TO DO THIS APPEARS TO BE AN OVERKILL. WAYNE L WEBER