Subject: File No. S7-14-08
From: Joel C. Carson, LUTCF
Affiliation: National Sales Director CLA USA

July 11, 2008

Annuities are in fact a form of a life insurance contract. As such this matter is best left to the contral and regulation of the state department of insurance. While true VA products fall under SEC regulation these "fixed" products inheirently have no market risk as the initial premuim is never at risk as the cleint can never loose any principal amount. As such these products need to stay under state control and regulation. Beyond that given the other investment products that seem to be negatively affeting ordinary investors I am at a loss why this is even on the agenda to regulate. If you cannot loose any principal by definiiton this should stay under DOI regulation.