Subject: File No. S7-14-08
From: Marvin D. Bowers

September 10, 2008

Gentlemen,
It appears the SEC is trying to control the market in an area where they do not belong. This is an Insurance Product. It is not "in" the market. The proformance is "indexed" to the market, but the guarantee of the FIA is also comparable to the Banking industry. Does that mean we are in the banking business. I don't think so
I don't pretend to know about securities and I don't recommend securities to my clients I only work in the area of Insurance products. The State Insurance Departments have seen to it we have proper "Disclosures" so why confuse the general public with more regulations and a prospectus no one ever reads completely any way.
Please let us do our job without any additional red tape. Our clients have been well informed (there are a few bad agents out there, but this is true in the securities market as well) and additional regulations will not help.
Thank You,
Marvin Bowers