Subject: File No. S7-14-08
From: Mark S Durfee

October 29, 2008

I am in aggreement that all fixed annuities should be considered securities. Annuities should be sold by licensed investment professionals. Purchasers of fixed annuities are investing dollars to use later. That purchaser is not buying an insurance policy he/she is investing money by contract.

Due to insurance agents not having professional investment education, too many clients are purchasing annuities like they purchase a pair of shoes. If the shoe seems to feel good and look good inside the store, the purchase is made. It is only days later that the shoe is discovered to be a bad purchase because it does not feel as good or does not look as they expected.

If a insurance agent/sales person has not been licensed and gone through training/qualified education (not from a product sponsor), how will that insurance agent/sales person know if the one investment product he/she can sell is right for the client. There are other securities and estate planning issues that the client needs to be aware of. If an insurance agent/sales person is licensed, trained, and educated, he/she will be more knowledgable to share all products and estate planning possibilities with his/her client.

I feel the investing public needs to feel confident they are dealing with an agent/investment professional that has gone through education and licensing and is regulated by the SEC and/or FINRA.