Subject: File No. S7-14-08
From: roy d corgill, life agent

July 10, 2008

I do not believe FIA's should be considered a securities product , by doing this you will do great harm to the industry and to the small investor trying to make a few more dollars on their savings without having to spend additional money for a brokerage account and an advisor.

I have been taking care of my clients for 20 years and have yet to have a complaint with these types of products.