Subject: File No. S7-14-08
From: Larry Black

July 1, 2008

Regulating Fixed Indexed Annuities as a Security is totally unnecessary. First of all they are guaranteed by an insurance company. The client can gain but not lose money.Secondly, this will effectivly take it out of the market I service, which is middle and lower income Americans. I don't have a securities license, and the agents that do as a whole don't service this market. I want to protect my clients as much as anyone, but this rule would only not do that, but limit Middle Americans access to what is becoming a valuable tool for them to accumulate wealth. Thank you, Larry Black