Subject: File No. S7-14-08
From: Joe W Spillman

September 3, 2008

I think that this Reg would hurt consumers because if Security reps are the only ones able to offer these products the consumer is less likely to be given it as an option. The broker dealer community has not embraced the FIA because they think that they are too good for it because it's not an "investment" and of course they are trained to sell "investments" not savings vehicles.

PS i agree with all of what else is said on teh SEC151a.com web site as well. See 10 points.

Joe