Subject: File No. S7-14-08
From: Mark A Pruitt
Affiliation: CEO, Strategic Estate Planning Services Inc.

July 10, 2008

I encourage the SEC to NOT make FIA's a security because they are fixed insurance products that are already highly regulated by the insurance dept. I am for tougher regulation to help inforce what good insurance agents are already doing. Those that present the product in the wrong way should be dealt with by tougher enforcement but making it a Security won't solve the issues.

Case in Point:

I see brokers promise the moon, tell people to hang on, that markets go up and down, in fact buy more while it's low and I have seen a 85 year old's 4 million dollar liquid estate lose 87% of it's value because it was placed in agressive growth funds and the best advice his broker could give him was....."hang on, it will come back."
The broker is right, but the problem is it won't be in HIS LIFETIME. Where is the regulation for the products the SEC already regulates? Whether its a Security or an Insurance Product the problem is not which side of the fence it sits on. It's the agent selling the product that may or may not be a good fit for the client.

Consider this:
Over $ 1 trillion in market value has been lost so far this year
35 of the 85 financial companies in the SP 500 have lost half their value
The SP lost $150 billion in one day alone

YET
Not one penny has been lost in a Fixed Indexed Annuity because it is a fixed insurance product, not a security. Let's keep it that way