Subject: File No. S7-14-08
From: Charles C. Guy
Affiliation: Financial Representative w/Northwestern Mutual

July 10, 2008

Against the proposed regulation by the SEC to make FIAs a registered security. The FIA, being a fixed product, is closely guarded as a core product by insurance companies. They are purchased for the same reasons as Fixed Annunities, CDs, and permanent life insurance. Since FIA's principal is protected against market fluctuations, purchasers assume tbe benefits and not the risk associated with securities. Changes suggested by the SEC will increase cost of FIAs thereby reducing their value to purchasers who want low risk investments. I am strongly against this proposed regulation.