Subject: File No. S7-14-08
From: Corwin S Freeman, Jr
Affiliation: President, Valley Estate Planners Ltd.

October 27, 2008

I feel that Professional Insurance agents can provide the best and most comprehensive explanation and due diligence for the sale of Fixed Equity Indexed Annuities for the following reasons. We are trained to make sure that the approprate vehicle is used for our clients., always looking over the long haul, not the short cut. A Fixed Equity Indexed Annuity is a FIXED/GUARANTEED product. When we talk to our clients about retirement, we're talking about a long time frame and Guarantees are at the heart of that time frame. Just look at the markets since 2000 My clients have NO WOORIES about their money because it is SAFE My referrals are through the roof because their friends accounts are plumeting and they know theirs are safe. That is the training we have, relationships not numbersI'm proud of my career of over 37 years and knowing my clients can sleep at night and so can I. Let Insurance professionals represent Insurance products and a FEIA is an INSUANCE product. There is NO MARKET RISK in a FEIA