Subject: s7-14-08

October 29, 2008

We at Cities Insurance Group find it interesting that the SEC continues to bombard the insurance industry with negative comments on FIA’s. As you know the stock market is in turmoil and yet the nearly FIFTY MILLION dollars we have placed in FIA’s for our clients are safe and secure. These ideals keep pace with the needs of the American public and the peace of mind they provide. Is it really the concern of the SEC that there are too many abuses or more that the flow of funds continue to fill the FIA programs by the billions.

I would believe the SEC should be MUCH more concerned with the current environment of the market and the TRILLION dollar losses the American public is realizing, not to mention the abuses I see in the market place of brokers investing funds for older citizens who shouldn’t be in the market. Many of these older Americans don’t know how they will continue their life style with 10 to 40 percent less in income due to these losses. It seems the SEC may have lost perspective of the value at hand and the “concern ie… File No. S7-14-08”.seems in our opinion misguided.

Cordially,

President CIG/RBI