Subject: File No. S7-14-08
From: John Hartman
Affiliation: Sole Proprietor

September 4, 2008

I agree that Fixed Indexed Annuities are not Securities. However, I do take issue with the dirty little secret that Broker/Dealers do not want publicized. To me, it is all about the money. They intend to collect fees from reps to which the B/D is not entitled, and encroaches on my income. Also, they want to mandate reps use only companies "acceptable" acceptable to the B/D. It offends me at the very core that retail B/D's intend to supercede the authority of state Insurance Commissions who already investigate and regulate these companies. That smacks of Restraint of Trade. As a licensed securities rep, I welcome reasonable regulation, but this is over the top. State insurance commissions already provide guidelines which accurately address suitability concerns for age and investment criteria. I urge you, as I have already urged my congressional representatives, to please accept that Fixed Indexed Annuities are NOT Securities, and that adequate quidelines are already in place to protect the general public.