Subject: File No. S7-14-08
From: William A Smith, Jr.
Affiliation: President, Great Lakes Retirement Group

September 5, 2008

Chairman Cox,

As a well respected financial advisor who educates clients on ALL of their investment options in the market, Fixed Indexed Annuities have NEVER been offered to our clients as a vehicle to compete against a security. Clients come to us for safety of their principle. I have met many people who have lost money in a security or a variable annuity, where that person really did not want to lose money. In fact most of the time the broker had sold these allocated portfolios or variable annuities as a safe account Indexed annuities are a great savings vehicle for people who want to potentially get a better rate of return than in a CD or other safe account. We have many satisfied clients that have had some fabulous rates of return in Fixed Indexed Annuities ranging from 0-20%. Also what is important to note, the average client that has money in the stock market is currently down over 10%. None of our clients that have money in an indexed annuity have lost any principle or interest, despite the markets downturn. This rule will ultimately hurt the consumer. The American people who believe in this great savings vehicle deserve to have a thorough and fair explanation before a rule of this magnatude goes into effect. We have several hundred satisfied clients that understand the definition of safety. Indexed annuities are a great safe alternative to CD's, money market accounts and government bonds, NOT A SECURITY When properly utilized, Fixed Indexed Annuities provide GREAT stability when combined with a quality portfolio of at risk investments.

Regards,

William "Bill" Smith, IAR
President
Great Lakes Retirement Group