Subject: File No. S7-14-08
From: Monty M Miller
Affiliation: 39 Year Life Insurance Agent

September 3, 2008

I am opposed to this move. Fixed annuities should not be governed by the SEC. They are fixed products, no risk to the client and offered by thousands of qualified life insurance agents across this country. Several things will happen if this proposed rule takes place. The most important in my mind is the small customer, that does not have huge investment portfolios will be left out in the cold. Brokers normally do not want to talk to people that do not have large sums of money to invest. Most of the work we do is with individuals who are looking for safe, sound financial products, without risk. Our clients have ZERO risk and all of the planning we do is safe money planning, ie life insurance(no variable), and fixed annuity products. The states do an excellent job of governing our industry, and have for decades.

Monty M. Miller