Subject: File No. S7-14-08
From: David W Matthews
Affiliation: CLU

August 11, 2008

True indexed annuities that are not variable are entirely insurance products. When the principal is guranteed that they can not lose it at the 100% level, that gives what ever product the insurance definition. If what they put in can go up or down, then I agree with you. That is like a true variable annuity.

To think you are even considering counting life insurance or health insurance as a security is going way too far. This is stretching the hand of the SEC way beyond what it was intended for. Please reconsider your actions so they make true legal sense. Thank you.