Subject: File No. S7-14-08
From: John F Lalley, CFP
Affiliation: Raymond James Financial Services

August 25, 2008

The area of indexed annuities is one of concern, due to poor information, both on the part of unqualified representation and unknowing consumers. Because I feel a knowledge gap exists and that it is in the best interest of the general public, I feel the product should require a licensed security agent to sell and explain. I am for the new and improved security regulation that is proposed.

The indexed annuity is a very safe,and attractive way to allow more conservative investors to have an opportunity to achieve a good return and in many cases improve their return over a regular fixed income investment. However, because of confusion, misuse and is some cases abuse it is a very misunderstood investment product.

Regards,
John Lalley