Subject: File No. S7-14-08
From: R. Neil Sperling, LTCP
Affiliation: Vice President, Financial Markets Inc

September 4, 2008

I own and sell Fixed Index Annuity. FIA's are a safe, secure financial instrument with rock solid guarantees. It is not a security. SEC oversight would cause additional expense to the design of FIA's and make them non-salable because they will be weighted down with fees and regulation. Please reconsider your position.