Subject: File No. S7-14-08
From: JOEL F. HOLMES , JR. CLU, ChFC
Affiliation: SOCIETY OF FINANCIAL SERVICE PROFESSIONALS

August 29, 2008

I AM VERY CONCERNED ABOUT YOU MAKING FIA TO BE UNDER YOUR CONTOLLED AS THIS IS AN INSURANCE PRODUCT AND IS NO WAY A SECURITY. ALSO I FEEL YOU WILL BE PUTTING MANY VALUABLE AND ETHICAL INSURANCE PROFESSIONALS OUT OF BUSINESS AND RESTRAINING BUSINESS OPPORTUNITES TO MANY YOUNG PROFESSIONALS WHO WANT TO ENTER THE INSURANCE FIELD. AFTER 49 YEARS IN THE INSURANCE BUSINESS I FEEL YOU ARE UNDERMINING MY PROFESSIONAL ETHICS BY TRYING TO PLACE EVERY AGENT UNDER THE FALSE ASSUMPTION THAT EVERY INSURANCE AGENT IS UNETHICAL. PLEASE TAKE A GOOD LOOK AT THE SECURITY INDUSTRY YOU REGULATE AND ASK YOURSELF OUR YOU DOING AN EXCELLENT JOB IN CONTROLLING THE MANY DECEPTIONS BY BROKERS AND THE ANSWER IS NO.

SINCERELY, JOEL HOLMES