Subject: File No. S7-14-08
From: Ross Raymond

October 14, 2008

I have worked in brokerage houses on and off for years and have been in the insurance business for 25 years. There is nothing to suggest the sales process of FIA is anything like what I have witnessed first hand in the sales of VA products.

The emphasis of the FIA is on security with the potential to do better than a CD rate, IF the market moves in a favorable direction. The emphasis on the VA sales is that we will double your money as soon as possible, but of course the past is no assurance the future will be as kind, and you Mr. Prospect, won't have to pay current taxes on all those gains.

Insurance agents understand the difference between preservaton of capital and hyping the next great thing to show up on the quote screen. FIAs are not all that romantic and the very people who can benefit from them most, are not the usual "stock broker" client as the sales are usually smaller and stay on the books much longer than the typical broker is willing to take on.

Let's weed out all poor sales practices in all products and leave FIA's as is with licensed insurance professionals presenting them to their clients.

With Respect,
RR
Katy, TX