Subject: File No. S7-14-08
From: Philip A Whiteman

July 11, 2008

As a Licensed Insurance Representative in Indiana, I have spent considerable time working with "Senior" clients in preserving their Savings which was previously invested in Bank CD's or Retirement plans. The use of Fixed Indexed Annuities, provides them with 100% protection of their Principal and protects them from market fluctuations. Therefore, my clients are not desirous of working with those who sell mutual funds, variable annuities or maintaining a brokerage account. In addition, this "proposed rule change" by the SEC will dramatically harm consumers and "force them" to a brokerage account for access to a Fixed Index Annuity.