Subject: File No. S7-14-08
From: Allan A. Beck
Affiliation: Cornerstone Financial Services

November 4, 2008

I fully agree with the reasons stated below as to why the SEC should not take action in defining FIAs as securities. Also, it would have a significant negative impact upon my business practice and complicate my ability to effectively make appropriate reccomendations to my senior clients.

Allan A. Beck
Cornerstone Financial Services
117 Moodys Island Road
Nobleboro, Maine 04555