Subject: File No. S7-14-08
From: Stanley C Cohen
Affiliation: CLU

July 11, 2008

I completely support the SEC in classifying the FIA as a registered product thereby limiting sales to be made by registered representatives who have the proper training and who have to meet strict compliance guidelines and suitability rules in the process of factfinding and helping people recognize what is an appropriate product to put their hard earned dollars in to for the future. The ruling if passed will certainly go a long way in discouraging some of the unscrupulous sales practices and inappropriate reccommendations made by sales people who are only interested in making a sale of the limited product available to them to sell, while not revealing full disclosure of the downside to the potential clients, particularly regarding the hefty surrender charges for early withdrawal for a lengthy amount of years.