Subject: File No. S7-06-04
From: DON DAVIS

September 4, 2005

IT WOULD BE HELPFUL TO THOSE WHO INVEST IN ANNUITIES TO REQUIRE ANNUITY COMPANIES TO PUT WORDING IN THEIR PROSPECTUS AND CONTRACTS WHICH ADDRESSES 1035 EXCHANGES. CURRENT WORDING ADDRESSES SURRENDERS AND PARTIAL SURRENDERS, BUT NOT 1035 EXCHANGES. I RECENTLY REQUESTED A PARTIAL 1035 EXCHANGE, BUT THE ANNUITY COMPANY WHERE I AM CURRENTLY INVESTED DOES NOT ALLOW PARTIAL 1035 EXCHANGES. THIS DOES NOT SEEM FAIR. THEY ARE BEING OBSTRUCTIVE IN ORDER TO PRESSURE ME INTO EITHER KEEPING MY FUNDS INVESTED THERE LONGER, OR TO COMPLETE A 100 1035 EXCHANGE WHICH WOULD CAUSE ME TO PAY INCREASED DEFERRED SALES CHARGES. IF I HAD KNOWN THIS AHEAD OF TIME, PERHAPS I WOULD HAVE NOT SENT THEM MY LAST PAYMENT OF 15,000 WHICH IS NOW SUBJECT TO DEFERRED SALES CHARGES IF I DO THE EXCHANGE.