Subject: File No. S7-14-08
From: Larry E. Ratcliff
Affiliation: Life Insurance agent and Registered Rep

August 10, 2008

Although I am a Registered Rep, I oppose making making the
sale of indexed annuities, a fixed product, to be considered
a security which would cause this product to not be available
for sale by the industry's fine life insurance agents unless they become Registered Reps.
I became a licensed life, health, and disability agent in
Feb of 1970, and I do not believe the SEC's help is required
in regard to the sale of indexed annuities. This is a fine
fixed product that should be available for sale to clients of
all the thousands of life, health, and accident agents.