Subject: File No. S7-14-08
From: Heth T Thomas
Affiliation: Financial Representative

July 10, 2008

Having sold these IA's in the past, I had convinced myself of their appropriateness in cases where clients were concerned about safety plus potential returns. However, Few, if any, of my clients have been satisfied w/ the results are availing themselves of the penalty free withdrawal provision. I sincerely believe the only one who gains here is the agent who collects an exhorbitant commision. Wihout proper regulatory oversight, I believe that agents will continue to sell these more for the commission than to truly meet the client's needs. My primary company, Northwestern Mutual, seems to agree with me since we are prohibited from marketing these products. The SEC should regulate these just like a VA.