Subject: File No. S7-14-08
From: John R Kelso

October 17, 2008

The only indexed annuities that should be regulated are those with only a single crediting method.

For example, say an indexed annuity has as its only chance to make positive results just one indexed crediting method, with no declared rate possible.

Any indexed annuity that allows a declared rate in combination with an indexed rate should be exempt from the new proposed ruling.

Why?

Angry consumers can simply switch their crediting method to the declared rate on an annual basis.

Problem solved.