Subject: File No. S7-14-08
From: Robert D. Penrod
Affiliation: Certified Senior Advisor

September 8, 2008

The very idea of the SEC attempting to make FIA's a security is a prime example of a government agency trying to create a problem when there is, in fact, no problem, then justifing their existence in solving this "problem". FIA's are not a security product the consumer has no risk period The principle is not at risk, nor are the earnings of previous years. The use of an outside element as a measurement of growth, for example, the growth of a stock index, is no different than useing the value of government bonds, or treasury notes as a benchmark to measure returns on whatever product we are offering. As a voter it is important to me that legislators use common sense in regard to these matters, and not allow themselves to be persuaded by government agencies who are simply trying to justify their existence in this manner. Thank you.